PTM160100 - Information and administration: essential principles: information and administration overview
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Record keeping
Who needs to provide information about pension schemes under the tax rules
Information notices
Operating relief at source (RAS)
Reclaiming tax on investment income
Self Assessment tax returns
Record keeping
There can be a number of different persons involved with a pension scheme, including the members, employer, trustees, pension provider and scheme administrator. Each may have administrative responsibilities in relation to it and each may employ agents. For example the scheme trustees may employ accountants, fund managers, actuaries and specialist third party pension administration companies to help them run the pension scheme.
Pension schemes keep lots of information and records to help support their administration. To ensure schemes pay the correct amount of benefits to the correct person when due schemes need to keep comprehensive records. The bigger the scheme the more records they need to keep.
Examples of records that may be held in respect of a pension scheme are:
- pension scheme trust deed and rules
- personal details for each scheme member
- application forms to join a scheme
- forms to request a transfer
- bank statements
- valuation reports
- contracts to purchase or dispose of an investment
- tax vouchers
- PAYE records and forms
- schedules of contributions.
This is not a complete list; generally for any action taken by a scheme there should be a piece of paper or an electronic record to act as an audit trail for the action.
The tax rules require those acting for a scheme to keep records for a minimum period, generally at least six years - see PTM160200.
Pension scheme trustees, scheme administrators and their agents will also be bound by the provisions of the Data Protection Act.
Who needs to provide information about pension schemes under the tax rules
The following people have a role in providing information about pension schemes:
- scheme administrators - see PTM160300,
- members - see PTM160400,
- employers - see PTM160500,
- scheme managers of qualifying recognised overseas pension schemes (QROPS) and former QROPS - see PTM160600,
- scheme managers of qualifying overseas pension schemes and corresponding schemes - see PTM160700,
- insurance companies - see PTM164500 and PTM109000.
Information notices
HMRC can make a bespoke request for information under a formal information notice. Any relevant person can be asked to provide information under a notice relating to a registered pension scheme, its registration or the scheme administrator’s status, and for QROPS. See PTM169000 for more information.
Operating relief at source (RAS)
Where a scheme gives tax relief on member contributions under the ‘relief at source’ system the scheme administrator must get certain information from the scheme member - see PTM044220.
Guidance for scheme administrators on how to reclaim RAS tax relief is published on gov.uk at:
https://www.gov.uk/pension-administrators-reclaim-tax-relief-using-relief-at-source.
If a scheme administrator reclaims RAS tax relief they should also make an annual information return to HMRC. Guidance about this is also published on gov.uk at:
https://www.gov.uk/pension-administrators-ras-annual-information-returns.
Reclaiming tax on investment income
It is usually the pension scheme trustee’s responsibility to administer a claim for repayment of tax withheld by investment providers. Guidance on the process for when income tax can be reclaimed and the reclaim process is published on gov.uk at:
https://www.gov.uk/pension-trustees-reclaim-tax-deducted-from-investment-income.
Self Assessment tax returns
HMRC may ask scheme trustees to complete a tax return: SA970 form “Tax Return for Trustees of Registered Pension Schemes” as an information return. Guidance about this is published on gov.uk at:
https://www.gov.uk/pension-trustees-self-assessment-tax-returns.
Scheme administrator tax charges are not reported and paid under the Self Assessment system. With the exception of the scheme sanction charge, scheme administrator tax charges should be reported and paid using the Accounting for Tax return - see PTM162000.
A member or employer may also be personally liable to a tax charge, such as the unauthorised payments charge or the lifetime allowance charge. These should be reported on their tax return.