Contributions to pension schemes made under a mistake as to the tax consequences could be rescinded, and an appeal against the revocation of a fixed protection certificate for lifetime allowance purposes by HM Revenue and Customs (HMRC) was allowed. 
 
Background 
 
The appellant was advised by an actuary to apply for fixed protection for pension saving lifetime allowance purposes (under FA 2011, Sch 18, para 14). A certificate of fixed protection was subsequently obtained in January 2012.  
 
The appellant did not understand that his standing orders for contributions to two personal pension schemes had to stop as a condition of fixed protection. Consequently, he did not take any steps to notify the bank to stop making the standing orders, which therefore continued after April 2012 (i.e. until April 2015). 
 
The appellant’s actuary