Ross Welland examines the 2020 Upper Tribunal case of HMRC v Sippchoice concerning in-specie pension contributions. He covers the facts, the case itself and the implications of the tribunal’s decision.
The recent Upper Tribunal (UT) decision, HMRC v Sippchoice [2020] UKUT 0149 (TCC), has the potential to leave self-invested personal pensions (SIPPs) – where in-specie contributions have been made – facing HMRC demands for repayment of tax relief.
The UT had to decide whether contributions made by four members of a SIPP were paid within the meaning of the legislation and therefore whether they could qualify for income tax relief at source. As the facts and circumstances of each investor were broadly the same (other than the level of contribution), both the First-tier Tribunal (FTT) and UT referred solely to papers produced for one of the investors, Mr Carlton.
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