Computing personal lifetime allowance

[FigNewton]

I will shortly need to apply for individual protection IP2016. My personal lifetime allowance will be based on a valuation of my pension savings at 5 April 2016. However at that date my SIPP had not yet received the HMRC top up on contributions I had made in March. Will I be able to include that top up amount within the sum that I seek as my personal LTA? Probably the top up will be added at the end of May. That would seem fair as this is contributions I made from salary in the previous tax year. The only reason the money was not in my SIPP at 5 April is because of delay by HMRC in paying. Perhaps someone came across this question as regards IP2014.

[FigNewton]

My SIPP provider claims not to know the answer to the question. Calls to HMRC helplines have also been fruitless. My own research has now taken me to the Finance Act 2014, which defines the rules for IP2014. I assume the rules for IP2016 will be the same. In Schedule 6 I read

Amount C (uncrystallised rights at end of 5 April 2014 under registered pension schemes) 4 Amount C is the total value of the individual’s uncrystallised rights at the end of 5 April 2014 under arrangements relating to the individual under registered pension schemes of which the individual is a member as determined in accordance with section 212 of FA 2004.

This leads me to believe that money which was still with HMRC at 5/4/16, but which was contribution from my wages in the tax year 2015-16, should count as uncrystallised rights and can be included in my valuation of savings for the purposes of IP2016.

[jason13]

I cannot answer your specific question, but when you make a contribution to a SIPP towards the end of tax year 1 and receive the tax relief in tax year 2 both amounts (i.e. the grossed up amount of your contribution) count as a contribution in tax year 1 for the purpose of your annual allowance.

I don't see a reason why it would be different for the individual protection.