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Other cases that caught our eye 14 April 2023

Pension liberation scheme: Dalriada Trustees Ltd and others v HMRC [2023] UKFTT 314 (TC) (21 March 2023) is a stark illustration of what can go wrong with pensions liberation schemes and how people caught up in them can end up in in dire financial circumstances by making unwise decisions. The arrangement [PRP] here was designed to enable people to access money from a pension scheme before the age of 55 without suffering any tax consequences. Reduced to its essential the planning involved reciprocal arrangements between pension schemes all under common trustees. Person A would transfer his/her pension out of an existing scheme into a new scheme X: Person B (unconnected) would transfer his/her pension from an existing scheme in new scheme Y. A would then get a loan from scheme Y and B would get one from scheme X. The intention was no tax charges would arise as...

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