Fixed protection 2014 revoked due to late contribution

The taxpayer intended to retire on 30 December 2013 but his employment was extended to 28 February 2014. He made his final employee contribution to his self-invested personal pension (SIPP) on 14 March 2014. He obtained a fixed protection 2014 (FP2014) certificate in respect of the pension lifetime allowance granting him protection from 6 April 2014. However his employer made its final contribution to his SIPP on 5 May 2014 – after the cut-off date of 5 April 2014.

As a result HMRC revoked the FP2014 certificate.

The taxpayer appealed. He said he had no control over the payment made by his employer and that HMRC should have exercised discretion in his favour.

The First-tier Tribunal considered the evidence in detail and concluded that the fact was that the employer’s contribution was made after the deadline and that it remained in his SIPP. HMRC was correct to revoke...