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Revenue Publish Guidance on Pension Scheme Levy

Revenue has published Tax Briefing Issue 04 which clarifies the 30 June valuation date for the purpose of calculating the 0.6% stamp duty levy on pensions and the limited exception to the 30 June valuation date provided for in paragraph (b) of the definition of “chargeable amount” in respect of defined benefit occupational pension schemes and one-member small self-administered schemes.

Section 4 Finance (No.2) Act 2011 inserted a new section 125B into the Stamp Duties Consolidation Act 1999 which provides for an annual stamp duty of 0.6% of the market value of assets held for the purposes of pension schemes approved by the Revenue Commissioners under Irish tax legislation.

The market value of those assets is taken on 30 June for each of the years 2011 to 2014. A limited exception to the 30 June valuation date is provided for in respect of all assets held in defined benefit occupational pension schemes and one-member small self-administered schemes but other than contracts of assurance. The legislation provides that pension assets can be valued at 30 June or they can be valued on the last day of the accounting period of the scheme ended in the period of 12 months immediately preceding 30 June.

According to the Tax Briefings article, the purpose of this exception is to avoid placing the administrative costs on certain schemes of having to undertake a separate valuation for assets as at 30 June in circumstances where a valuation for those assets already existed in the most recent scheme accounts.

Readers are reminded that in order for a date to be valid as a valuation date the chargeable person must have held the assets concerned as administrator or insurer on that date.

The full text of Tax Briefing Issue 04 is published on the Revenue website at http://www.revenue.ie/en/practitioner/tax-briefing/2011/no-042011.html