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Small Self-Administered Scheme - Trustee's Borrowings

The content of this page is based on our understanding of how pensions worked before A-Day, the 6 April 2006, and is provided for reference only.

It is possible for small self-administered scheme (SSAS) Trustees to borrow money from a lender e.g. a bank, to purchase, or help purchase scheme assets. This may enable Trustees to buy much larger assets than they would have been able to using only existing scheme funds. The Trustee's borrowings can be secured or unsecured, they must however be on commercial terms.

The maximum amount that Her Majesty's Revenue and Customs (HMRC) will allow the Trustees to borrow is a sum equal to the total of:

  • 3 times the ordinary annual contribution (see notes below) paid by the employer, plus
  • 3 times the annual amount of basic or contractual contributions paid by the scheme members (excluding AVCs) in the tax year ending immediately before the Trustee's borrowings, plus
  • 45% of the market value of the assets of the scheme (see notes below.)

Notes

Ordinary annual contribution means the smaller of:

  • the average annual amount of contributions including special contributions (i.e. singles), but excluding AVCs, paid to the scheme in the 3 scheme years immediately before the date of the borrowing, and
  • the amount of the annual contributions which, within the period of 3 years immediately preceding the date of the borrowing, an actuary has advised in writing would have to be paid in order to secure the benefits provided under the scheme.

45% of the market value of the assets of the scheme must exclude:

  • any portion of funds notionally underpinning retired members’, ex spouses’, widows’, widowers’ or dependants' benefits in payment where the annuity had been deferred
  • any sums borrowed to purchase scheme assets which are outstanding at the time of borrowing and any other liabilities incurred by the Trustees which are outstanding at the time, other than liabilities to pay benefits under the scheme.

The limit to the maximum amount of Trustee’s borrowings applies at the date the borrowings take place. The maximum amount will not be re-tested at a later date, even if there is a change of circumstances.

Any money borrowed must be used to benefit the scheme. If the Trustees decide to use this money to lend to the employer, or an associated employer, then a higher rate of interest must be charged than the SSAS is paying to borrow the money.

Existing loans

If the scheme Trustees have previously borrowed money and some of this is still outstanding, the amount outstanding at the time of the new loan must be deducted from the market value of the scheme assets before the 45% is calculated.

Example

Date of Trustee's borrowings – 1 July 2004
Scheme accounting date – 1 June
The amount that the actuary has advised that would have to be paid in order to secure the benefits provided under the scheme - £75,000 p.a.
Amount of outstanding borrowings - £25,000

Contributions to the scheme in the last 3 years

CONTRIBUTION PERIOD

CONTRIBUTION

TOTAL

1 June 2001 – 31 May 2002

annual - £50,000
special - £15,000

£65,000

1 June 2002 – 31 May 2003

annual - £65,000
special - £10,000

£75,000

1 June 2003 – 31 May 2004

annual - £70,000

£70,000

Average is £70,000

Value of scheme as at 1 July 2004 

ASSETS

VALUE

Insurance policies

£50,000

Unit trusts

£20,000

Commercial property

£120,000

Quoted shares

£50,000

Trustee bank account

£20,000

Total assets

£260,000

Maximum Trustee borrowings:

= (3 x 70,000) + (45% x [£260,000 - £25,000])
= £210,000 + £105,750
= £315,750

Scheme been in existence for less than 3 years

If a scheme has been in force for less than 3 years the total amount of contributions paid since the scheme commenced until the time of the Trustee's borrowings is divided by the number of years within that period, with a part year being counted as one year e.g.

Commencement date - 1 January 2003
Accounting date - 1 March
Date of Trustee's borrowings - 1 April 2004

Period 1 = 1 January 2003 to 28 February 2003
Period 2 = 1 March 2003 to 29 February 2004
Period 3 = 1 March 2004 to 1 April 2004

Therefore you would divide by 3.

Example

Commencement date – 1 January 2003
Date of Trustee's borrowings – 1 April 2004
Scheme accounting date – 1 March
The amount that the actuary has advised that would have to be paid in order to secure the benefits provided under the scheme - £25,000 p.a.

Contributions to the scheme in the last 3 years

CONTRIBUTION PERIOD

CONTRIBUTION

TOTAL

1 January 2003 – 28 February 2003

annual - £8,000
special - £5,000

£13,000

1 March 2003 – 29 February 2004

annual - £10,000
special - £5,000

£15,000

1 March 2004 – 1April 2004

annual - £2,000

£2,000

Average is £10,000


Value of scheme

ASSETS

VALUE

Insurance policies

£15,000

Unit trusts

£5,000

Trustee bank account

£6,000

Unquoted shares

£8,000

Total assets

£34,000

Maximum Trustee borrowings:

= (3 x 10,000) + (45% x £34,000)
= £30,000 + £15,300
= £45,300

Other lenders

It is possible for the scheme Trustees to borrow money from someone other than a bank or building society e.g. the principal employer. If money is borrowed from a connected party then HMRC must be sent a copy of the loan agreement so that they can check that the loan is on commercial terms.

Reporting requirements

In most cases HMRC must be advised of any Trustee borrowings using HMRC form PS7015. However, the borrowings do not need to be reported:

  • where the money is borrowed for 6 months or less, and
  • the aggregate amount does not exceed the lesser
    • of 10% of the market value of all the scheme assets, and
    • £50,000.

If however the transaction does need to be reported, then within 90 days of the Trustee borrowings taking place, HMRC must be advised of full details. Failure to meet this requirement can incur financial penalties and jeopardise the scheme's approval.

After A-Day

Details on Trustee's borrowing after A-Day (6 April 2006) can be found using the attached link.



The information provided is based on our current understanding of the relevant legislation and regulations and may be subject to alteration as a result of changes in legislation or practice.

All references to taxation are based on our understanding of current taxation law and practice and may be affected by future changes in legislation and the individual circumstances of the investor.

Updated 6 July 2005

For professional advisers only