Contributing to a SIPP within the Annual Allowance when DB Pension benefits data unavailable

My wife would like to supplement her workplace DB pension from the Scottish Public Pensions Agency (SPPA) with a cash addition to a SIPP before the end of the tax year, whilst ensuring that any additional pension contribution is within the annual allowance, taking into account any unused allowances accumulated over the past 3 years. Unfortunately the pension provider have experienced significant delays in providing Pension Savings Statements (PSS’s) to employees, with statements for 22/23 and 23/24 tax years still outstanding. This is apparently due to complexities associated with applying the 2015 Remedy. The PSS statements are essential to determine the capitalised growth of the pension benefits (i.e. the effective contribution in a DB pension) in each pension input period. These delays in historical pension statements obviously makes it extremely difficult for employees to calculate the level of unused pension allowance. Compounding this, under no circumstances would the PSS for 24/25 be available under after the end of the current tax year again making it difficult to ensure that any additional SIPP contribution is with the annual allowance. Given the circumstances, can you please advise what should be done in these circumstances to ensure compliance with the pension allowance limit and avoidance of the Annual Allowance Tax.

Hi ,
 

This is financial advise which HMRC are not authorised to give. You will therefore want to discuss with a financial adviser . Thank you .

Thanks for the reply, and understand you cannot give specific financial advice. To your point, we have consulted with a financial advisor on this matter, but he has been handicapped by the lack of information available from the pension provider (SPPA) who are not accepting emails queries or phone calls regarding pensions savings statements. Can you please confirm if the HMRC are aware of these delays? if so, what allowances will be made to safeguard individuals from incurring penalties or tax should they unwittingly exceed allowances, due solely to the inability of the pension agency to provide key information on a timely basis? Thankyou.

Hi Alex D,
Each case would then be looked at in its own merit if/when any penalties were applied.
Thank you.

But that's for penalties... Exceeding the Annual Allowance doesn't incur a penalty, it just creates liability to pay the appropriate tax. It would be surprising if the tax was not held to be payable in full once figures became available, no?

That was my point too, better made by maxb. Surely there should be some blanket dispensation made to protect affected individuals from the imposition annual allowance tax, where the pension provider is unable to provide the information necessary to for an accurate determination of unused allowance? Going back to my earlier note, could you please answer my question regarding HMRC's awareness of the delays with the SPPA?

Hi maxb,
It is up to you to work out and declare any excess over your tax free threshhold, paid into a pension scheme, in a Self Assessment tax return.
There are no penalties for paying in more to your pension pot that the tax free limit.
Thank you. 

Hi Alex D,
We can only provide general information / guidance in this forum. We cannot comment on delays in this forum.
Thank you.