Private and confidential

Pensions Consultation 2015,

Pensions and Savings Team,

1 Horse Guards Road,

London

SW1A 2HQ

29 September 2015

Dear Sir/Madam,

Strengthening the incentive to save: a consultation on pensions tax relief

Introduction

The Northern Ireland Tax Committee of Chartered Accountants Ireland is pleased to have the opportunity to comment on the above consultation document published in July 2015.

Members of this Institute play an important role in pensions. Many of our members are trustees of pension funds, finance directors responsible for pension scheme strategy or are otherwise involved in pensions policy/administration in the course of their day to day professional duties.

We would be happy to discuss any aspect of these comments and to take part in any further consultations/initiatives in this area that there may be in the future.

We wish to briefly comment on this consultation.

Stability

We recognise that this consultation has been badged as somewhat of an opening salve to considering how the current system may be reformed and thus no specific proposals have been put forward at this point. We look forward to future consultations which may contain more specific proposals for comment.

We note the principles for reform outlined in Chapter 3 of the consultation document and are supportive of these. However we believe that equally essential principles for building trust and confidence in the pensions system and encouraging pension saving are certainty and stability.

At this early stage we wish to stress the importance of ensuring any options considered will result in a much more stable system for pension saving. The current system has seen many changes in recent years with further changes due to come into operation next April as a result of the Summer Budget. Box 2.A on page 13 of the consultation document clearly depicts the instability of the current regime.

Conclusion

As noted in the consultation document, the UK pensions system is recognised as complex. A complex system can make people believe the financial incentives to save are weaker than they actually are.

Over recent years, individuals have been subjected to a barrage of complicated and often conflicting information about the future of their pensions which has left them confused and uncertain about the state of their retirement provision or indeed what steps they should be taking. Individuals can only make informed choices about how they provide for their retirement if the pensions system introduced following this consultation is simple, certain and long term.

However it will be crucial to protect those already saving for their retirement via the current regime. These individuals should have the choice to stay in the current regime they have already engaged with or move to any new regime if they so desire. Many employers and individuals have invested heavily in the current regime and auto enrolment is still at a very early stage.

Freedom of Information

We note the scope of the Freedom of Information Act with regards to this submission. We have no difficulty with this response being published or disclosed in accordance with the access to information regimes. This response will be published on our own website and will be available to all of our members and the general public.

Do not hesitate to contact Brian Keegan (brian.keegan@charteredaccountants.ie) or Leontia Doran (leontia.doran@charteredaccountants.ie) of this office should you require anything further.

Yours faithfully,

Paddy Harty

Chairman

Northern Ireland Tax Committee

Chartered Accountants Ireland

Source: Chartered Accountants Ireland. www.charteredaccountants.ie.