Readers’ forum: What payments are counted before breaching allowance?

My client has her own company which pays pension contributions to a self-invested personal pension (SIPP) in her name. She has paid the annual allowance amount via her independent financial adviser (IFA) for several years so I had believed that she has no unused allowance brought forward.

This year she has asked if she can pay £60 000 to the pension fund and the the adviser’s 3% commission separately to the IFA without breaching the annual allowance.

My reading of the HMRC guidance suggests that the annual allowance is the amount paid into the pension fund so the IFA’s commission doesn’t count towards the £60 000. Is there any reason she cannot do this or anything that should be done to make sure there is no question? Is it possible that she has unused allowance from past years if the IFA’s charges were taken...