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Dunne (SpC 654)
The taxpayer was a member of L's approved occupational pension scheme between 1980 and 1996 and would have been entitled to a pension from his 60th birthday in 2019.
On 24 September 2001, the accrued pension benefits of £43,632 were transferred to H's pension scheme, which required that the person must be an employee of H Ltd.
The insurance company issued the taxpayer with a single premium annuity of £43,632 to start in 2034. Two days later the taxpayer received a loan of £33,600 secured against the annuity and repayable in 2034.
H Ltd's annual PAYE return for 2001
