Over-taxed, over here

My client is a consulting engineer English domiciled and resident here. He is a director and major shareholder in an American company based in Texas which operates through a UK branch which he runs.

This branch is registered at Companies House and accounts prepared by a London firm of accountants are filed with HMRC.

In the past few years both the branch and the American company have been very successful and the profits from the UK branch have all been distributed by way of a pension contribution (from his employer the UK branch) to his pension scheme.

The contributions have been in excess of £200 000 a year for the past few years. There is no danger of my client exceeding the £1.5m lifetime allowance limit.

I am aware of HMRC’s recent re-interpretation that suggests that my client may now be able to use his...