Since our last update, the practical difficulties facing
employers and pension trustees in dealing with the impact of the
pensions levy created by the Finance (No 2) Act, 2011 (the
"Act") have started to emerge. This update focuses on
those practical issues assuming that the levy has been paid.
To recap on some key points:
- The levy had to be paid through the Revenue On-line Service
(via the administrator if the scheme is not registered) or on or
before 23rd September (as the 25th was a Sunday).
- Insured assets had to be valued at 30 June 2011 and the levy
was payable by the insurer. Most insurers deducted the levy from
assets invested with them on or shortly after 30 June 2011 and have
already remitted it to the Revenue prior to the due date. If scheme
assets include insured and non-insured assets the levy would have
been partly paid and the actuary/administrator would then have
advised on the remainder amount of the levy to be paid by 23
September.