The April 2015 tax changes

Transcription

1 OFFICIAL PARTNER The April 2015 tax changes A practical guide for trustees

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3 The April 2015 tax changes 3 Contents 1. April 2015 tax changes a reminder 4 2. How is my scheme affected? 5 3. Issues for DC arrangements 6 4. Issues for DB arrangements Annual allowance and other changes Contacts 18

4 4 The April 2015 tax changes April 2015 tax changes a reminder Highlights From 6 April 2015, the Government is introducing what it calls the most radical changes to pensions in almost a hundred years. New laws will create scope for individuals to have completely flexible access to their defined contribution (DC) pension savings at retirement. The reforms will affect a huge number of pension schemes, not just DC-only schemes, and have wide-ranging implications. With less than three months to go, trustees need a plan for responding and quickly. Many trustees will already be receiving detailed member enquiries. This is a practical guide explaining the reforms and setting out steps trustees should take to prepare for them. It is relevant to trustees of DC and defined benefit (DB) pension schemes. The Budget 2014 announced fundamental changes to the way in which members of DC pension arrangements can access their benefits in the future. Key changes already in force include: An increase to the overall pension savings that can be taken as a trivial lump sum from 18,000 to 30,000 An increase in the size of a single pension pot that can be taken as a lump sum (regardless of overall pension savings) from 2,000 to 10,000 An increase in the capped drawdown limit from 120% to 150% and a reduction in the minimum income requirement for flexible drawdown from 20,000 to 12,000. Key changes from 6 April 2015 include: Ability for individuals to withdraw their entire DC pension pot from normal minimum pension age (typically age 55), subject to their marginal income tax rate Removal of the limits on drawdown A new duty on pension providers and trust-based pension schemes to signpost the Pension wise guidance guarantee service at the point of retirement. This guide examines the changes that are coming into effect from 6 April 2015 in more detail and considers the practical steps trustees will need to take in order to get ready for those changes.

5 The April 2015 tax changes 5 How is my scheme affected? The extent to which an individual can take advantage of the new rules on drawdown or the payment of their benefits as one or more lump sums (the New Flexibilities ) will, in part, depend on the type of benefits they have. The first step for trustees is to establish what type of benefits the scheme provides. Trustees should take legal advice on this point. In tax law, benefits fall into the following categories: DB arrangements such as final salary benefits. DC arrangements: conventional where member and employer contributions plus investment returns build up into a pot that is converted into benefits at retirement. cash balance the member builds up a fund in a similar way to a conventional DC arrangement the difference is that there is a promise as well, such as a particular rate of investment return or interest on the fund. Hybrid arrangements where the type of benefit depends on what comes into payment. For example, members in a DC scheme that was contracted-out on a salary related basis will have a hybrid arrangement. If the value of the member s contracted-out underpin is higher when the member retires, the arrangement is treated as a DB arrangement. If, however, the value of the member s DC fund is higher, it is a DC arrangement. Hybrid arrangements are particularly complex and schemes containing them will need specialist advice. The New Flexibilities apply only to DC arrangements and hybrid arrangements where the benefit at retirement is DC. It will not be mandatory to provide the New Flexibilities (see page 8). However, schemes that do not offer the New Flexibilities will still have to address a number of practical issues (for example updating their member communications see pages 10-12). There will also be an impact for DB arrangements as more members may want to transfer out of their existing DB scheme to take advantage of the New Flexibilities. Individuals can have more than one arrangement in the same pension scheme. For example, a member of a final salary scheme who has paid AVCs to provide extra benefits has two arrangements in the same scheme a DB arrangement for the final salary pension, and a DC arrangement for the AVCs. Trustees of DB schemes that have members with DC AVCs will therefore need to consider issues for both DB and DC arrangements.

6 6 The April 2015 tax changes Issues for DC arrangements The headlines Schemes containing any sort of DC or hybrid arrangement will be directly impacted by the reforms and should already be planning their response, keeping a close watch on how the legislation develops in the period up to 6 April Here is a route map for trustees looking to navigate the issues in the coming months. Step 1. Understand the reforms and the new options for taking benefits. Step 2. Consider whether scheme can offer the New Flexibilities (check scheme rules and statutory override). Step 3. Identify the options. Step 4. Select an option decide whether (and how) the scheme will offer the New Flexibilities. Step 5. Communicate decision to membership and deal with member queries in run up to 6 April Step 6. Plan for short and longer-term changes to member communications and investment options. Step 7. Implement changes to at-retirement and communication processes in time for 6 April Step 8. After 6 April 2015; review and update other scheme communications to reflect new options. Review investment options. Step 1. Understanding how the New Flexibilities work The reforms will change the payments that DC arrangements are allowed to make within tax law from 6 April The following diagram gives an overview of the basic options that will be available for accessing DC arrangements from 6 April 2015 (and how this is changing from the current position in tax law). Money purchase arrangement Changing: Lifetime Annuity Changing: Drawdown New: Cash lump sum(s) No change: Scheme pension

7 The April 2015 tax changes 7 Type of benefit What is it? Is anything changing? Other notes Lifetime Annuity Drawdown Cash lump sum(s) Scheme pension Member s savings used to buy an annuity from an insurer. The member designates some or all of their savings as a flexi-access drawdown fund to provide payments, either from the scheme or with a third party provider. New option, allowing members to take their savings as one or more lump sums (known as an uncrystallised funds pension lump sum ). Can only be used for uncrystallised funds (that is, savings not already set aside to be used for scheme pension, lifetime annuity or drawdown). Member's pension savings converted into a pension payable from the scheme. Also known as internal annuitisation. While DC schemes will still have to give members the option to buy an annuity, current restrictions will be relaxed to allow more flexible types of annuity where payments can change from year to year. Current limits on drawdown are being removed, allowing complete flexibility to take money out of the fund as the member chooses. Special rules will apply to individuals who have already set up drawdown arrangements before 6 April Schemes that allowed members to do this should take specialist advice. Uncrystallised funds can be paid out as one or more lump sums, subject to income tax at the individual s marginal rate and additional conditions. No Tax free cash (pension commencement lump sum) available with this option. Tax free cash (pension commencement lump sum) available with this option. Special annual allowance rules will restrict further DC saving when this benefit is taken after 6 April 2015 (see page16) Up to 25% of the lump sum can be paid tax free. Special annual allowance rules will restrict further DC saving when this benefit is taken after 6 April 2015 (see page.16). Internally annuitised pensions become a defined benefit when the pension comes into payment and may be rare in practice. In addition it will no longer be possible to pay trivial commutation lump sums of up to 30,000 from a DC arrangement. These are being replaced by the uncrystallised funds pension lump sum.

8 8 The April 2015 tax changes Step 2. Can the scheme offer the New Flexibilities? Schemes will not be compelled to provide the New Flexibilities. Instead there will be a permissive statutory override allowing schemes to provide them if they wish to do so. How does the statutory override work? The statutory override will be fundamental to implementing the reforms as it allows trustees to make any of the new types of flexible payment even if the scheme rules would prohibit the payment. Interestingly there is no need for the scheme s sponsoring employer to consent. However in practice, we would expect trustees to want to liaise with their employer over benefit design issues of this nature. Other points to check will include: Any existing scheme rules that would allow members flexible access to their pension savings. This could include a rule giving members a wide option to choose any sort of benefit payment permitted by pension tax law. Current scheme rules about taking benefits as a lifetime annuity. If the rules currently set out detailed conditions, should these be updated (or the statutory override used) to allow members access to new flexible types of lifetime annuity if these become available? Step 3. Identifying the scheme s options Since schemes have a choice about offering the New Flexibilities, there needs to be a decision about what (if anything) to offer. Broadly, the basic options are: Member More flexibility Scheme More complexity Option 1 Offer completely flexible access with payments coming directly from the scheme/arrangement. Option 2 Allow members to access their savings as single or periodic lump sums (that is, allow uncrystallised funds pension lump sums) directly from scheme, but require more complex arrangements such as drawdown to be set up outside with a third party provider. Option 3 Require members who want any sort of flexible access to transfer out. Less flexibility Less complexity

9 The April 2015 tax changes 9 Alternatively, trustees and employers might decide not to offer the New Flexibilities immediately, but to monitor developments and revisit the position in the future. In that situation: The trustees will still need to update their communications and processes in time for 6 April 2015 (see below). The scheme rules, and the possibility of an increase in transfer requests, will need to be considered (see page 10: what if the trustees and employer do not want to offer the New Flexibilities?). Step 4. Should the scheme offer the New Flexibilities? Whilst some trustees and employers may have reservations about moving their scheme away from providing traditional pension payments, personal choice has always been a feature of the DC environment. Trustees will want to engage with the scheme s employers at an early stage there are numerous benefit design and practical considerations to balance. Employer views on benefits the scheme should provide, particularly access to pension savings whilst still employed. Suitability of existing benefit options. Implications and costs of flexible access/multiple lump sum payments for scheme and member. Changes to communications at and before retirement. Provisions of current scheme rules. Additional scheme governance and monitoring. Likely considerations Member regret risk and complaints to scheme or employer. Any additional costs and charges for member. Member demand and member views. Impact of more members transferring out as an alternative. Capacity of scheme/existing providers to offer flexible access. Implications for current investment options.

10 10 The April 2015 tax changes What if the trustees and employer do not want to offer the New Flexibilities? If the decision is to offer no (or only limited) flexible access from the scheme, bear in mind that: Trustees will need to check whether any existing options in scheme rules need to be curtailed to give effect to this decision. Particular care should be taken with wide scheme rules entitling members to any payment that would be an authorised payment under pension tax law. There may be increased demand for transfers out. Following changes to legislation on transfers, deferred members of DC schemes will have a statutory right to transfer their benefits at any time before the benefit is crystallised (that is, before funds are used to purchase an annuity or scheme pension, or designated as available for drawdown). It will be important to make sure that members are clear about any charges for transferring out. Step 5: Communicating the decision Once the trustees and the employer have decided their approach, they should consider communicating this to members as matter of good practice. This will allow members who are looking at retirement or early access from 6 April 2015 onwards to understand what their likely options will be and whether they will need to transfer out. Such a communication may also be helpful in managing member enquiries. It may therefore be desirable to issue the communication sooner rather than later. Steps 6-8: Communication and implementation issues Understanding and implementing the guidance guarantee In this area, there are four practical actions for trustees to consider as a priority: Trustees will have a statutory duty to tell members about the guidance guarantee. We are awaiting amendments to disclosure regulations that will set out what information occupational pension schemes will have to provide, how, and when. Giving members information about their benefits. The Government has announced that schemes will be required to provide details of DC benefits the member has accrued, in an easily usable format to help members make the most of the guidance guarantee. We await further details of exactly what is required. Reviewing retirement communications and benefit statements. Trustees will need to revise their existing scheme communications for compliance with the new requirements. In particular, there may need to be significant changes to documents that refer to the member s options for taking benefits. It would be sensible to start this review. Where changes to at-retirement processes and communications are needed, the systems will need to be in place by 6 April Trustees may want comfort that their providers will have capacity to do this work given the short timescales and to consider whether interim arrangements need to be made to ensure that members retiring or transferring soon are given accurate information. What is the guidance guarantee? Members will have a right to free guidance on the choices for their DC benefits at retirement referred to as the guidance guarantee. The Goverment has recently announced the service will be branded as Pension wise. The Government has also announced that: The guidance will be provided by independent third parties including the Pensions Advisory Service (TPAS) and the Citizens Advice Bureau (CAB). Other providers including charities may be approved in the future. The service will be funded by a levy on regulated financial services firms. The Financial Conduct Authority will set up and supervise new standards for the guidance. Individuals will be able to access guidance in a range of ways, including face to face if they wish. Guidance will cover issues wider than pensions including welfare and social care.

11 The April 2015 tax changes 11 Implications for investment options A higher proportion of members may want to use their DC savings to target transfers or flexible access to cash at retirement, and trustees will need to consider whether the existing range of investment options is suitable in this context. Trustees will want to consider their investment powers under the scheme rules and discuss the issues in depth with their professional investment advisers. Particular points to consider will include: Taking advice on whether existing default funds and lifestyling options remain suitable given that members may want to access or transfer their savings earlier than retirement, and more flexibly. Deciding on appropriate investment options if members are allowed to retain DC savings in the scheme to use for drawdown or periodic lump sums. Monitoring for potentially suitable new options as the market develops. Considering withdrawal of any options that are no longer suitable. Communicating changes to the investment options to members. Communicating with members Effective communication is one of the cornerstones of the DC regulatory regime. Schemes face several challenges in responding to the Budget reforms in this area: Early enquiries. Trustees are already dealing with member enquiries in the run up to 6 April Interim communications need to be clear about the position and manage expectations appropriately, especially in the period before any decision has been taken about how the scheme will respond to the reforms. Providing additional information. Although members have a right to the guidance guarantee, schemes will be free to top this up with additional information. Some trustees and employers may feel this is appropriate for their member population, particularly if: there is already an annuity broking, financial advice, or similar service in place members are going to be required to leave the scheme in order to access their benefits flexibly. It is important that additional communications do not constitute regulated financial advice. The individual s decision about how to access their DC pension savings will be highly nuanced and dependent upon personal circumstances. There will be a number of points of detail which may only affect a small number of members in practice, but could have a significant impact where they do apply. Individual decisions: complex choices It is proposed that where an individual uses a drawdown product to access their DC savings flexibly, the money held in the drawdown account will not be counted towards capital means testing for social care which may be needed in old age. However, if the individual takes all of their DC savings as a cash payment and places unused funds into a bank account, it is highly likely the pension money in the bank account would count towards the means test. This could be a significant factor in individual choices. It is intended that the guidance guarantee will cover the impact on welfare and social care. Other potentially complicated areas include any rights (such as the right to a guaranteed annuity rate at a specified age) or early payent charges attaching to existing DC funds; and the implications of having funds in a drawdown account or other flexible access arrangement in the event of personal insolvency. Trustees will need to understand the issues so the scheme can deal with any cases that arise.

12 12 The April 2015 tax changes Communicating throughout the member journey. The new guidance guarantee and disclosure obligations will focus on information at and around the time benefits are taken. However, trustees and employers will already be aware that effective communication is essential throughout the member journey. Given the implications for members investment choices and the extent of the reforms generally, trustees would be well advised to look at all of their scheme communications more widely. Regulatory guidance. Pensions Regulator DC quality features in this area are likely to be reviewed to reflect the new flexibility. Looking ahead, trustees and employers may therefore wish to plan for different communication issues at different pinch points see the suggested timeline below. Communications timeline Autumn 2014: technical consultation on legislation. Autumn 2014: legislation in Parliament. Start liaising with employer. Consider high level response to member enquiries given no final decision on offering flexible access, and draft legislation. Consider updating high-level response to reflect technical detail and any decisions taken? Consider putting extra resource onto communication and retirement process in short-term. Now: January March April Continue responding to member enquiries and consider issuing a member announcement with definitive statement of the scheme s position. Update retirement process and communications to cover new options and guidance guarantee. Implement new retirement and guidance guarantee processes. Expect a spike in member requests following scheme announcement, and a backlog of members who postponed retirement to wait for reforms. After April Consider a general review of scheme communications to ensure new options accurately described and sufficient information is available to members. Consider whether at-retirement resource and process will be sufficient longer-term.

13 The April 2015 tax changes 13 Issues for DB arrangements The headlines Taking flexible payments from DB arrangements will not be permitted, but members will be allowed to transfer their DB benefits to a DC arrangement and access the benefits flexibly from there. For trustees of DB arrangements, the key issues will include: Implementing additional safeguards for members transferring from DB to DC arrangements. Dealing with the implications of a larger number of transfer value requests from members. Transfers from DB schemes Transfers from DB to DC arrangements will continue to be allowed, meaning that members will, in effect, be able to convert their accrued DB benefits to DC and then take their pension savings flexibly. To address concerns that DB to DC transfers may sometimes be detrimental to members or the transferring scheme, two safeguards will be put in place: Trustees of the transferring scheme must ensure that the member has received appropriate financial advice from an independent financial adviser before transferring out. Guidance will remind trustees of their existing powers to reduce transfer values where a scheme is underfunded and to ask the Pensions Regulator to extend the time limit for making a transfer payment. Trustees existing powers Reducing transfer values. If a DB pension scheme is in deficit, trustees may be able to reduce transfer payments to reflect the level of underfunding in the scheme. Reducing transfer values helps prevent weakening of the scheme s funding position (and therefore of the security of benefits for non-transferring members). Trustees will need actuarial and legal advice on whether they can pay reduced transfer values. Delaying a transfer value. Trustees can ask the Pensions Regulator to extend the time limit for paying a transfer value beyond six months if, among other things, the interests of members or the scheme generally will be prejudiced by paying the transfer value within the normal period. The Government considers that these powers should be sufficient to keep schemes viable in the new environment. Transfer advice who pays? Where the transfer is to a DC arrangement within the same scheme, or is made as part of an employer-led transfer incentive exercise, the financial advice must be paid for by the employer. In other cases, the member will be liable to pay the cost of the advice. Transfer advice issues for trustees How trustees must ensure that independent advice has been taken is not yet known. Requiring a member to tick a box on the scheme s transfer request form confirming that s/he has received advice would not be too onerous but the legislation may go further than this. Trustees should watch for developments here. What if the member wants to act against the advice? It appears the law will only require a member to have taken advice, not to act consistently with it. Again, the position is not yet clear and trustees should monitor this. The requirement for the advice to be appropriate will need further clarification through legislation or guidance.

14 14 The April 2015 tax changes What might a greater number of transfers out mean? Whether and to what extent members with DB benefits will prefer to convert their accrued rights to DC and to access their pot flexibly is a great unknown. If large numbers do choose to transfer out this could significantly affect DB schemes. For example: Greater numbers of transfers out could result in reductions in scheme funding levels. If this happens, trustees should consider reducing transfer values accordingly. Potentially, increased transfer activity by single members or those with impaired life could cause a scheme s actuarial assumptions (on longevity and percentage of members married) no longer to be appropriate. Adjusting these assumptions to reflect higher average longevity or marriage rates could increase the scheme s liabilities and reduce the funding level. Trustees will need to ensure they have enough realisable assets to meet any increased demand for transfers in the short-term, as well as considering the longer-term implications of a change in the scheme s cash flow with their investment advisers. Trustees will need to ensure their administration procedures are robust and their transfer value calculations remain appropriate in line with market conditions and demographic changes to the scheme. Other issues relating to transfers Risk of complaints. Are DB trustees at greater risk of complaints from members who transfer out and later regret their decision? The requirement to take independent financial advice will help here, but trustees should also consider whether the audit trail clearly shows the member was informed about relevant risks and confirms understanding of them. Even where trustees could successfully defend a claim, doing so necessarily involves expense and time. Communication issues. As well as making sure the member takes independent financial advice and understands their own risk, trustees should ensure that members are clear about other implications of transferring out, for example: After transfer the DB scheme will no longer have to provide spouse s benefits in respect of the member, and funds transferred into a DC arrangement may be used in a way that provides no spouse s benefits Transfers may jeopardise lifetime allowance transitional protections such as fixed protection, unless HMRC requirements are met.

15 The April 2015 tax changes 15 Non-statutory transfers Statutory transfer rights will only be extended in relation to DC benefits (see page 10). Deferred members of DB arrangements will continue to have a statutory right to transfer these benefits only up to 12 months before normal pension age. DB members may mistakenly believe from comments in the press that they can transfer their rights at any time before retirement trustees will need to decide whether to allow non-statutory transfers and to manage member expectations appropriately. Issues to consider here will include: Do the scheme rules allow the transfer? The rules might only permit transfers where the member has a statutory right to transfer, or they might give the trustees or the employer a discretion to pay transfer values in other circumstances. What is the trustees policy around non-statutory transfers? Should these be calculated using the same procedures as statutory transfer values for consistency? Obtaining a discharge of liability. When trustees pay a statutory transfer value and certain conditions are met, they are automatically discharged from further liability to the member. The same is not true of non-statutory transfers and trustees should therefore require the transferring member to sign an appropriate waiver. The requirement on trustees to check that the member has taken appropriate financial advice before transferring DB benefits to a DC arrangement will also apply to non-statutory transfers. Where possible, scheme rules should allow the trustees or employer to refuse consent where the member does not supply satisfactory evidence of having taken advice. In some DB schemes, the cash equivalent transfer value for a member very close to normal retirement age can be greater than the cost of providing the member s benefits under the scheme, as calculated on the scheme funding ( technical provisions ) basis. For such a scheme, a significant number of older members choosing to transfer out could strain the scheme s funding position. The extent to which paying transfer values in respect of members nearing retirement will be detrimental to a scheme s funding position will depend on various actuarial factors if concerned, trustees should take advice from their scheme actuary. Money purchase AVCs Many DB schemes have facilities for members to pay (or to have paid in the past) AVCs to buy additional benefits, usually DC benefits. Typically, members will take their AVC fund as a pension commencement lump sum ( tax free cash ) in preference to commuting their scheme pension if scheme rules allow. In some cases, members may also use some or all of their AVC fund to buy a lifetime annuity to top up their DB benefits. Trustees of DB schemes with DC AVCs may well decide not to offer the New Flexibilities available from 6 April 2015 except, perhaps, allowing members to take their whole AVC fund as an uncrystallised funds pension lump sum. Trustees should note, however, that members will have a right to transfer their DC AVCs to another scheme without a corresponding transfer of their DB benefit (see the box on separate transfers overleaf).

16 16 The April 2015 tax changes Separate transfers of DB and DC benefits Historically, a member only had a statutory right to transfer all of their rights from a scheme together (subject to exceptions where a receiving scheme could not accept contracted-out rights). However, alongside the pension flexibility tax reforms, members will have new statutory rights to separate transfers of different categories of benefits held under the same scheme. Where DB members have money purchase AVCs, they will therefore have a statutory right to transfer the DB benefits and the money purchase funds separately should they wish. What is a benefit category? The legislation introduces three categories of benefits for the purposes of transfers between schemes. The statutory definitions are complex but, broadly, the categories comprise: Traditional final salary or career average defined benefits Cash balance benefits Money purchase benefits which are not cash balance benefits.

17 The April 2015 tax changes 17 Annual allowance and other changes Changes to the annual allowance The annual allowance is the yearly amount of pension savings an individual can save in a tax efficient way. It is currently 40,000. The Government wants to ensure that individuals do not use the New Flexibilities to avoid tax on their current earnings by diverting their salary into their pension with tax relief and then immediately taking 25% tax free. New money purchase annual allowance rules (the New Rules ) will therefore be introduced from April 2015 as follows: An individual subject to the New Rules will have a reduced annual allowance for DC savings of 10,000. They can also accrue defined benefits. The rules setting out the amount of the remaining annual allowance for a member accruing both DB and DC benefits are complex, but broadly: where DC savings in the tax year are 10,000 or less, the individual will retain a total annual allowance of 40,000 plus any unused annual allowance carried forward from the previous three tax years; an individual whose money purchase savings in the tax year exceed 10,000: will be subject to the annual allowance charge on the excess DC savings over 10,000; and will have a reduced annual allowance of 30,000 (the alternative annual allowance ) for their DB savings, plus any unused annual allowance carried forward from the previous three tax years. Designating funds to a drawdown fund after 6 April 2015 and taking an associated tax free pension commencement lump sum will not, on their own, trigger the New Rules. The New Rules will only apply where an individual actually takes money out of the drawdown fund (whether as income drawdown or a short term annuity) or takes an uncrystallised funds pension lump sum. Special rules will apply where an individual subject to the New Rules is accruing benefits in a hybrid arrangement. Pension scheme administrators are required to provide members whose additional contributions or accruals in a tax year exceed the annual allowance with a statement showing the value of their further savings. Individuals who become subject to the New Rules by drawing flexible benefits from another scheme must give specified information to the administrator of each scheme (now and in the future) in which they are active members. A scheme administrator should keep careful records of which members are subject to the New Rules and must give the member a statement of the value of further savings if their annual DC contributions exceed 10,000. If a member subject to the New Rules transfers out, the administrator must also give specified information to the administrator of the receiving scheme. Changes to age at which benefits can be taken Normal minimum pension age this will increase from 55 to 57 in 2028 and then remain 10 years below state pension age thereafter. Trivial commutation and small pot lump sums from 6 April 2015: The limit on paying death benefits as trivial lump sums will also be raised from 18,000 to 30,000 for members who die after a specified date. A trivial commutation lump sum death benefit may be paid regardless of the age of the member at death (the current requirement that the member must have died aged under 75 will be removed). The small pot and trivial commutation rules will allow lump sums to be paid from age 55 rather than age 60 as at present. Trustees will need to check if the rules of their scheme allow payment of such lump sums from the lower age of 55 or whether a rule amendment is required. Tax charges. The current 55% tax charge on payments unused or uncrystallised funds left over after the member has died is being reduced or removed altogether, subject to conditions. Trustees may need specialist advice in this area. Date of this guide: January 2015.

18 18 The April 2015 tax changes Contacts This note is written as a general guide only. It should not be relied upon as a substitute for specific legal advice. Key Hogan Lovells Partners Katie Banks T katie.banks@hoganlovells.com Duncan Buchanan T duncan.buchanan@hoganlovells.com Claire Southern T claire.southern@hoganlovells.com Edward Brown T edward.brown@hoganlovells.com Pension360: the full picture About Pensions360 Hogan Lovells broad cross-practice capability covers the full spectrum of legal advice from lawyers who understand pension clients; advising on issues from scheme investments, corporate restructurings and transactions, to funding solutions and interaction with the Regulator or the courts. The ability to draw on specialists from other practices who are not only experts in their field but have an in-depth understanding of pension issues sets us apart from our competitors.

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