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Author: Glenn

What is the pension’s Money Purchase Annual Allowance?

The Money Purchase Annual Allowance (MPAA) is a pension rule designed to prevent individuals from gaining double tax relief on pension contributions. It targets situations where someone withdraws money from their defined contribution pension pot and then reinvests it, effectively receiving tax relief on the same funds twice.

The normal annual pension contribution limit is currently £60,000. However, once the MPAA is triggered the pension contribution limit is significantly reduced to the MPAA cap of £10,000 per year.

The MPAA is triggered when you start accessing your pension flexibly, such as by:

  • Withdrawing your entire pot as a lump sum (in full or in part).
  • Moving into flexi-access drawdown and taking income.
  • Buying a flexible annuity.
  • Exceeding withdrawal limits under a capped drawdown plan.

It does not usually apply if you:

  • Only withdraw up to a 25% tax-free lump sum allowance.
  • Buy a lifetime annuity.
  • Cash in a small pension pot of less than £10,000.

If applicable, the reduced pension allowance can affect future retirement planning and needs to be considered before making any pension withdrawals.

Tax Diary September/October 2025

1 September 2025 – Due date for corporation tax due for the year ended 30 November 2024.

19 September 2025 – PAYE and NIC deductions due for month ended 5 September 2025. (If you pay your tax electronically the due date is 22 September 2025)

19 September 2025 – Filing deadline for the CIS300 monthly return for the month ended 5 September 2025. 

19 September 2025 – CIS tax deducted for the month ended 5 September 2025 is payable by today.

1 October 2025 – Due date for Corporation Tax due for the year ended 31 December 2024.

19 October 2025 – PAYE and NIC deductions due for month ended 5 October 2025. (If you pay your tax electronically the due date is 22 October 2025)

19 October 2025 – Filing deadline for the CIS300 monthly return for the month ended 5 October 2025. 

19 October 2025 – CIS tax deducted for the month ended 5 October 2025 is payable by today.

31 October 2025 – Latest date you can file a paper version of your 2024-25 self-assessment tax return.

Company director disqualification

Company directors have a legal duty to act responsibly and in the best interests of their business. If a director fails to meet these responsibilities, they can face disqualification from acting as a company director for up to 15 years.

Disqualification can result from ‘unfit conduct,’ which includes actions such as trading while insolvent, failing to maintain proper accounting records, neglecting to submit statutory accounts to Companies House, not paying taxes or using company money or assets for personal benefit. It can also occur if a director is subject to bankruptcy or a Debt Relief Order.

The disqualification process typically begins when The Insolvency Service investigates a company involved in insolvency proceedings or responds to complaints. If misconduct is suspected, the director will be informed in writing and given the option to either defend the case in court or voluntarily accept a disqualification through a formal disqualification undertaking. Other authorities including Companies House, the courts or a company insolvency practitioner can also initiate disqualification proceedings.

Once disqualified, an individual cannot be involved in forming, marketing or running a company or be a director of any company registered in the UK or an overseas company that has connections with the UK. Breaking these rules can lead to a fine or imprisonment. Disqualified directors are listed on public registers maintained by Companies House and The Insolvency Service.

Applying for Home Responsibilities Protection

Did you know a missing Home Responsibilities Protection (HRP) record could reduce your State Pension, but you may still have time to put it right.

Home Responsibilities Protection (HRP) was a scheme designed to help individuals, mainly those with caring responsibilities, to build entitlement to the basic State Pension by reducing the number of qualifying years required. HRP applied between 6 April 1978 and 5 April 2010, after which it was replaced by National Insurance (NI) credits.

Although most eligible individuals received HRP automatically during that period, some cases were missed. It’s still possible to apply for HRP retrospectively if it’s missing from your NI record. This is particularly relevant for women at or near State Pension age, especially those who took extended time off work to raise children. A missing HRP record could affect your State Pension entitlement, although not always.

Those affected should check their NI records for gaps and could potentially increase their State Pension at no cost. If a claim is successful, HMRC will update the NI record, and the DWP will recalculate the State Pension amount. This could lead to an increase in the State pension, though in some cases, it may remain unchanged.

Currently, HRP applications are taking over 3 months to process. For the most recent processing times and to check the status of an existing claim you can visit the official HMRC guidance page at www.gov.uk/guidance/check-when-you-can-expect-a-reply-from-hmrc

Tripartite arrangements don’t necessarily enable an agency to escape accountability

The question was raised as to whether, in a tripartite agency relationship, an employment relationship exists between an employee and their intermediary agency. For instance, Ryanair DAC employs some pilots directly, while subcontracting others. A Mr. Lutz successfully applied to an advertisement for pilots and was contracted on 10 August 2017 by MCG Aviation Ltd. (now Storm Global Ltd.). From July 2018 to January 2020, Mr. Lutz served as a Ryanair-contracted pilot based at Stansted, nominally supplying his services through his own Irish company, Dishford Port Ltd., although it is now accepted that his direct relationship was with MCG. 

Following an incident with Ryanair management on 13 January 2020, MCG terminated its contract with Dishford, effectively ending Mr. Lutz's services. He then brought two claims to tribunal with the support of the British Airline Pilots Association (BALPA) concerning annual leave against MCG under the Civil Aviation (Working Time) Regulations (CAWTR) 2004, and also an equal terms claim against both MCG and Ryanair. Through this action, Mr. Lutz was seeking compensation for not being afforded the same working conditions as employed pilots under the Agency Workers Regulations (AWR) 2010. 

The tribunal found in Mr. Lutz's favour, holding that he was a "crew member" employed by MCG under CAWTR and also an "agency worker" under AWR. Subsequent appeals by Ryanair and MCG were dismissed as, where a worker is supplied by an agency (B) to a principal (C), but has an explicit contract with the agency, the agency remains the employer. Mr. Lutz's services to Ryanair were thus explicitly governed by his contract with MCG, which expressly stated that he was not employed by Ryanair. The fact that Ryanair exercised exclusive direction and control over Mr. Lutz's work does not necessarily create an implied employment contract or relationship with Ryanair, although it befell MCG to ensure that Ryanair respected the relevant employment laws. Moreover, even though Mr. Lutz had a fixed-term contract for several years, it was nonetheless "temporary", thereby creating a gap in protection for agency workers and introducing ‘unacceptable uncertainty’. 

This case reinforces the "substance over form" approach in determining employment status, in that employers can no longer solely rely on contractual labels such as "independent consultant" or "self-employed" as a pretext to deny workers their employment rights, especially in such tripartite agency arrangements. Thus, agencies should understand that workers employed for extended fixed terms are likely still covered by the AWR and thereby entitled to the same T&Cs as direct employees after 12 weeks. Hence, agencies still have clear responsibilities for certain statutory rights, and businesses relying on "supply chain layering" to outsource labour will need to review their structures.