Transfers of assets to self-invested personal pension plans were not ‘contributions paid’ for tax purposes, there was no debt obligation, a return must be rendered before the discovery provisions were invoked, and the appellant did not act in accordance with the practice generally prevailing.

Summary

Transfers of assets to self-invested pension plans (SIPPs) were not ‘contributions paid’ for tax purposes, there was no debt, a return must be rendered before the discovery provisions were invoked, and the appellant did not act in accordance with the practice generally prevailing.

Background

The appellant, a provider and scheme administrator of registered SIPPs, made annual claims for tax relief at source. Those claims were made in respect of contributions made by individuals to their SIPPs for the tax years 2012/13, 2013/14 and 2015/16. During those relevant tax years,