Property Guide

MC Trustees
(PENSIONS) LIMITED
Property Administration Guide
MC Trustees Private Pension
The information provided in this document is a summary of our
requirements in respect of the purchase of commercial property
within a Self Invested Personal Pension (SIPP) held with MC
Trustees. It is based on our understanding of current law and
HM Revenue & Customs’ guidance at the date the document was
prepared. It should not be relied upon for advice purposes or
as a statement of fact or law. Please also note that current laws
may change in the future. If you require further information,
please contact your adviser or MC Trustees.
Version 3 March 2014
Version 3 March 2014
Contents
Summary of our Requirements
2
Part 1 What property your SIPP cannot buy
Residential Property
Conversion of commercial property to residential
Other property we will not permit your SIPP to buy
3
3
3
Part 2 Buying a property, including costs and our charges
Property Questionnaire
4
Property Valuation and Survey
4
Panel Solicitors
4
Cash balance
4
Insurance4
Property Purchase Requiring a Loan
4
Buying from You or a Connected Party
5
Lease5
Existing Tenants
5
Part 3 Charges and costs
Our Charges
6
Other charges and costs
6
Stamp duty
6
VAT6
Part 4 Tenant and On-going Property Issues
Lambert Smith Hampton
7
Property Management
7
Day to day contact with Tenants
7
Connected Tenants
7
Key responsibilities
7
Property works
8
Fixtures and fittings
8
Rent Collection
8
Service Charges
8
Rent Deposits
8
Rent Reviews
9
Invoices9
Development work
9
Part 5 Joint Ownership and Property Sales
Joint Ownership
Property Sale
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1
10
10
Summary of our Requirements
Please see below a summary of our requirements
– further information is provided later in this
document.
■■ You will need to complete our Property
Purchase Questionnaire before we can consider
agreeing to a property purchase. We reserve the
right to refuse an application.
There are certain types of property you
may not purchase in your SIPP, residential and
overseas properties being the main restrictions.
There are other restrictions with public houses,
bed & breakfasts/hotels and land. The restrictions
are explained later in this Guide.
■■
■■ We require one of our panel solicitors to
be appointed to deal with conveyancing
and the preparation of leases and associated
documentation.
We require an open market valuation and
open market rental value of the property before
purchase. The valuation must include the
reinstatement value of the property at the time
of purchase. We recommend that the property
be valued every three years following the date
of purchase. All valuations must be carried out by a
member of the Royal Institute of Chartered Surveyors
(RICS). Please note that the property must be valued
when benefits are taken from the SIPP.
■■
■■ We will obtain a quotation for property
insurance from our insurance brokers. As legal
owners of hundreds of commercial properties for
our SIPP, we require all properties to be insured
through the block policy. We review our block
policy annually to ensure it remains competitive.
■■ Post completion, all properties will be
administered on our behalf by Lambert Smith
Hampton (LSH). This is included in our standard
fees as set out in our Charges Schedule.
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2
■■ Neither we nor LSH provide property
management services. We strongly recommend
you appoint a property manager if you do not
live in the vicinity of the property to ensure the
property remains in good condition. LSH can do
this, subject to extra charges, and we will obtain
a quote from them should you so wish. We
reserve the right to insist on a property manager
being appointed if the property becomes vacant
as we need to ensure the condition of the
property does not deteriorate whilst empty.
■■ We require a minimum cash balance of one
quarter’s rent (or £5,000, whichever is higher) to
be held in the SIPP bank account at all times. If
the cash balance falls below this amount, we will
ask you to make a contribution or to liquidate an
asset to restore the minimum cash balance.
If the property needs to be opted to tax,
we will deal with the VAT registration and
subsequent completion of VAT returns.
■■
■■ We will not source a lender should borrowing
be required to facilitate the purchase of the
property, but we do have conditions which need
to be included in facility letters and will liaise
directly with the lender. Borrowing is limited to
50% of the net asset value of the SIPP under HM
Revenue & Customs (HMRC) legislation (with tax
charges on the SIPP where breached).
■■ Post completion, the property title deeds and
leases will be held by the solicitor who dealt with
the conveyancing, or by the lending bank should
there be a charge against the property.
Part 1 Property your SIPP cannot buy
Residential property
A SIPP may not acquire any interest in residential
property. If this happens, there are significant
tax consequences on both the SIPP and you
personally. Please see this link: www.hmrc.gov.
uk/manuals/rpsmmanual/RPSM07109060.htm.
These tax charges arise on acquisition and are
not discretionary. There are also on-going tax
implications.
There are a few exceptions, but these are very
strict. Please see our fact sheet “Residential
Property and your SIPP” for more information, see
Appendix 3.
The intention to convert a residential property to
commercial use is not sufficient reason to allow
a purchase of that residential property by a SIPP.
Similarly, the existence of planning permission to
convert residential to commercial does not make
the purchase acceptable. The determining factor
is whether the property is residential when it is
acquired by the SIPP.
Holiday properties and buy-to-lets are residential
and therefore prohibited. An intention to lease
out the property on an arm’s length basis does
not alter the fact that the property is residential.
Conversion of commercial
property to residential
You cannot convert commercial property to
residential. If you do, significant tax charges will
arise on completion of the conversion.
You may apply for planning permission to
convert to residential, but works to convert must
not be carried out whilst the property is owned
by the SIPP. Please do not apply for planning
permission without our agreement.
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3
Other property we will not permit
your SIPP to buy
■■
Hotel rooms (including time-share properties);
■■
Overseas property;
■■
Nursing Homes; and
■■
Land banking promotions
We do not permit land banking in SIPPs because
it is very difficult to ascertain the true worth
of the plots and there is evidence that in the
past these have been sold at inflated prices
through high pressure and unregulated sales.
The Financial Conduct Authority (FCA) have shut
down a number of land banking firms because
they have been operating illegally and are so
concerned they have put a warning on their
website. See the web-link address below:
www.fca.org.uk/consumers/scams/investmentscams/land-banking
We have similar concerns with hotel room
investments.
We will not normally permit the purchase of:
Land or woodland next to or near to your
house (see Appendix 4 “Buying land or woodland
near to your house”);
■■
■■ Bed and Breakfast or Public House premises, as
these are likely to be viewed as residential (see
Appendix 3 “Residential Property and your SIPP”
for an explanation of the only circumstances
where we will consider permitting such
properties to be purchased); or
Vacant property (unless there is an agreed
tenant to occupy).
■■
Part 2 Buying a property,
including costs and our charges
Property questionnaire
In order to determine whether the proposed
property is acceptable as a SIPP asset, you must
complete our Property Purchase Questionnaire
(PPQ). The PPQ asks for details of the property,
the purchaser(s), the tenants, and the VAT
position. It also contains the declarations we
require all purchasers to make.
Upon receipt of the completed PPQ, we will
determine whether the property is acceptable
as a SIPP asset and, if it is, we will contact the
relevant parties to commence the purchase.
Property valuation and survey
In all cases, we will require sight of a full “Red
Book” valuation of the property confirming:
■■
Description of the property;
An assessment of the property with
recommendation as to whether a full structural
and/or asbestos survey is required;
■■
A full schedule of recommended repairs
if required;
■■
■■ Re-instatement value of the property for
insurance purposes;
■■
Open market value of the property; and
■■
Open market rental value of the property.
The surveyor must be an independent,
professionally qualified individual, Member of the
Royal Institute of Chartered Surveyors (MRICS) or
equivalent. The survey report must be addressed
to us so that we can rely on it in the future. If the
SIPP is borrowing, the lending bank will require
the surveyor to be one on their panel; this is
acceptable provided the report is also addressed
to us.
We will also require a copy of site-specific
Asbestos Survey (requirement of CAWR 2006)
(where applicable).
Panel Solicitors
We have appointed the following panel solicitors:
■■
Lyons Davidson contact Catherine Turner
■■
Gateley LLP contact Elly Duggins
Solicitor fees for property purchase and related
services are summarised at Appendix 2. You
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4
must use one of these solicitors for purchasing
property in your MC Trustees’ SIPP.
Cash balance
We require a minimum of one quarter’s rent or
£5,000, (whichever is higher) to be held in the
SIPP bank account at all times. This provides
liquidity for payment of invoices, insurance etc.
where they are the responsibility of the Landlord.
Should the cash available fall below the
minimum required, we will require a contribution
to be made or another asset of the SIPP to be
liquidated in order to provide the cash.
Insurance
Properties must be placed on cover at exchange
of contracts.
The premium will be settled by the tenant, unless
the property is vacant or the terms of the lease
state otherwise.
Property purchase requiring a
loan
If your SIPP needs to borrow money to assist
with the property purchase, you must ensure
that all borrowing does not exceed 50% of the
net asset value of the SIPP, in accordance with
HMRC legislation. This limit includes all existing
borrowing by your SIPP.
Example
A SIPP already holds a property with
borrowing. The assets are as follows:
■■
a property with a market value of £200,000
a loan of £50,000 still outstanding with
a bank
■■
■■
cash of £100,000
The net value of the SIPP is £250,000 (the
£300,000 assets minus the outstanding loan
of £50,000).
The maximum borrowing permitted under
HMRC rules is £125,000. But as there is an
existing loan of £50,000, the SIPP can only
borrow a further £75,000.
The HMRC test is applied at the date of
completion, not on receipt of the Property
Purchase Questionnaire (PPQ) or exchange
of contracts. Please bear this in mind when
calculating whether you can borrow enough
to acquire your chosen property, taking into
account the different costs and taxes potentially
due. Please note that the value of the property
being purchased is not included in the valuation
of the SIPP.
We will contact your chosen lender on receipt of
the completed PPQ and inform them how the
loan is to be structured.
Lease
If the property is not being purchased with the
benefit of an existing lease, the solicitor will
prepare a new lease which will be on a fully
repairing and insuring basis. The lease will include
details of the term, the rent amount, the rent
review date, insurance and details of possible
service charges. It will also set out the respective
tenant and landlord on-going responsibilities.
We have various conditions, including the way
the title is registered and a limitation of our
liability to the assets of your pension fund. The
limitation wording is there to ring-fence the SIPP’s
liability from all other members. We will discuss
our requirements directly with your chosen
lender.
Once the lease has been drafted and agreed, it
will be signed by MC Nominees Limited as the
landlord and by the tenant. The original lease
will be held by our panel solicitor. A copy of the
signed and dated lease will be supplied to the
tenant and to you the Member.
The solicitor will liaise with the lender in respect
of any Legal Charge required.
Existing Tenants
Important:
If your SIPP defaults on the required loan repayments
because there is insufficient cash in your SIPP to
meet the required payments, your property may be
repossessed.
Buying property from you or
from a Connected Party
A SIPP can buy property from you or a connected
party, but the transaction must be at market
value (the definition of “Connected Party” is as
set out in Section 993 of Income Tax Act 2007).
The transaction must be supported by an
independent valuation by a RICS valuer.
If the SIPP buys at an over value (or we sell at an
under value), both you and the SIPP will be taxed
on the difference. We will not knowingly do this.
We can lease property to your business or a
connected party but the annual rental income
must be supported by an independent valuation
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and a commercial lease. See the Connected
Tenant section in Part 4 on page 7.
5
Should there be a lease in place at the time of
purchase, this will remain until the end of the
term. The existing lease may allow for nonquarterly payment periods and the terms of the
insurance may also differ from our standard lease.
It is important that the required RICS property
market valuation reflects the terms of the existing
lease. We would expect the valuer to reference
these existing terms in their report.
LSH will contact the tenant following completion
of the property purchase to advise them about
the new landlord and also to direct payment of
rent to LSH.
Part 3 Charges and costs
Our charges
Our charges for property purchase and
associated activities are set out in our charging
structure, a copy of which is attached at
Appendix 1.
The charges quoted are for standard property
purchase administration, and include our ongoing charges as well as costs on acquisition. We
reserve the right to charge for additional services
on a time-cost basis relevant to the expertise and
seniority of our staff involved. We will provide
an estimate of all such additional charges as
applicable.
Unless we advise you to the contrary, all work
carried out by LSH on our behalf is covered by
our standard property fees.
Other charges and costs
In addition to the purchase price of the property,
you must consider:
■■
The solicitor’s fees (see Appendix 2);
■■
Stamp Duty Land Tax;
■■
VAT that may be payable on purchase;
■■ Valuer/surveyor costs, and any costs for
environmental reports;
■■
IFA or, if borrowing, bank fees; and
■■ Our requirement that at least £5,000 cash (or
one quarter’s rent if higher) is held after purchase
in the SIPP bank account.
Stamp duty
Stamp Duty Land Tax (SDLT) is due on
commercial properties as follows:
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Purchase Price
SDLT Rate
£0 to £150,000
Zero
£150,001 to £250,000
1.00%
£250,001 to £500,000
3.00%
Over £500,000
4.00%
6
Where a property is transferred into the SIPP
as an in-specie contribution, then SDLT will be
payable on the value of the property as stated in
the transfer deed.
Where the SIPP only purchases part of a property,
SDLT will be payable on the value of the share
purchased. Where property is contributed ‘inspecie’ in stages, we will need to take advice to
ensure the staged transactions do not represent
linked transactions for SDLT purposes.
VAT
The SIPP can register for VAT if the property to be
purchased is opted to tax.
If the SIPP is already VAT registered we will need
to complete an option to tax form in respect of
the property to be purchased.
We will complete the VAT registration and any
option to tax documentation. We will also
complete the quarterly VAT returns.
If the property is opted to tax, VAT is chargeable
on the rent and on all expenses of the landlord
which are reclaimable from the tenant.
Part 4 Tenant and on-going property issues
Lambert Smith Hampton (LSH)
Connected tenants
Following completion of the purchase of the
property, the administration of the property will
be carried out by LSH. (www.lsh.co.uk).
Where there is a tenant that is connected to you
(for example, a business that you control), then,
there is a potential for a conflict of interest.
Our main contact at LSH is Chris Berry and he can
be contacted by email at [email protected] or by
telephone on 020 7198 2357.
To deal with this conflict of interest, it is important
you understand and accept that all relationships
between the SIPP and tenant are carried out on a
fully arm’s length basis. The property must always
be administered in the best interests of the SIPP.
Their duties include:
■■ Collection and disbursement of rent;
■■
Collection and distribution of service charges;
■■
Rent deposits;
■■
Payment of insurance premiums by the tenant;
■■
Implementation of rent reviews;
■■ Day to day contact with tenants when
necessary;
Liaising with Tenants regarding rent arrears and
appointing litigation solicitors if necessary;
■■
■■ Payment of any maintenance invoices and
reclaim from the tenant if applicable;
■■
Sale of the property at the due time.
There are also a number of other important
issues of which you need to be aware. Our fact
sheet “Leasing Commercial Property from your
SIPP” explains these issues in more detail and is
attached at Appendix 5.
Key responsibilities
The important points from Appendix 5 are:
A fully commercial lease must be signed before
the property is occupied and the rental terms
must be supported by an open market valuation
prepared by an independent RICS qualified
surveyor. The solicitor handling the purchase will
deal with the drafting of a new lease if required.
■■
As all dealings with the SIPP must be on arm’s
length commercial terms we outsource all ongoing work relating to your occupation of the
property to an arm’s length commercial property
administrator, LSH. There is no extra fee for their
involvement.
■■
Property management
Neither we nor LSH will manage the property.
A property manager actively manages
the property, to preserve the value of the
property and its income potential. We strongly
recommend you appoint a property manager.
We are likely to insist that a property manager be
appointed in the following circumstances:
■■ Where you or a party connected to you is
leasing the property and rental arrears arise;
■■
The property becomes vacant; or
■■ There is borrowing which goes into default
because there is no cash in the SIPP to fund loan
repayments.
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■■ You must inform LSH immediately if you are
struggling to make rental payments due.
You must clear in advance with LSH any
proposed work on the property.
■■
■■ You cannot convert the property to residential
and we cannot own any items that are not fixed
(and are what HMRC call ‘tangible moveable
property’). Please see the link to the HMRC
website for further explanation www.hmrc.gov.
uk/manuals/rpsmmanual/RPSM07109120.htm).
Day to day contact with tenants
■■ You must ensure the property is maintained to
an acceptable standard as required by the lease
(once signed).
LSH will have full contact details of the tenants
and should any problems arise, LSH will be the
first point of contact.
■■ Prior to any sub-letting, you must obtain
the approval of the landlord (which must be
permitted by the lease).
If the matter can be resolved immediately, LSH
will notify you that the issue has been concluded.
If the matter cannot be resolved immediately,
LSH may need to discuss the matter directly with
you and/or us.
■■ You must inform us immediately if the property
is vacated and ensure the property is protected
following vacation. We will provide you with
a guide informing you what is required by the
insurers to ensure the insurance is not invalidated.
7
Property works
The SIPP can only pay for work that is the
landlord’s responsibility. All work must be cleared
in advance with LSH. Also, we must appoint the
contractor, and pay them directly from the SIPP.
You must not take any commission or fee from
the contractor.
Fixtures and fittings
We are not permitted to buy or own any item
that is moveable (what HMRC defines as ‘tangible
moveable property’ see link above).
Acquiring such assets triggers tax charges in
exactly the same way as residential property
(collectively HMRC refers to both residential
property and tangible moveable property as
‘taxable property’ and taxes them accordingly).
In the context of commercial property, anything
that is viewed as a ‘chattel’ will generally be
classed as ‘tangible moveable property’.
Common examples include:
■■
furniture;
■■
carpets;
■■
plant & machinery;
■■
white goods; and
■■
solar panels.
Generally speaking such assets should be tenant
expenses and should not be acquired by the SIPP
as landlord.
If in doubt, please check with LSH.
Rent collection
Rent will be collected by LSH on the usual quarter
days which are for England, Wales and Ireland 25
March, 24 June, 29 September and 25 December.
For Scotland the dates are 28 February, 28 May,
28 August and 28 November. The rent collection
dates may be different should the lease be in
existence prior to the property being purchased.
LSH will transfer the rent collected to your
SIPP bank account usually within a maximum
4 working days of receipt. Should rent not be
received, LSH will contact the tenant to request
immediate payment. LSH will check the terms of
the lease for any late payment interest due and
will invoice the tenant accordingly.
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8
If the tenant falls into serious arrears, the matter
will be referred to the solicitors who dealt with
the conveyancing and in extreme cases the
matter will be placed into the hands of a bailiff
for repossession of the property. This applies to
both connected and non-connected tenants,
although with the latter we will usually be led by
your instructions.
Where the tenant is either you or your business,
or any other party connected to you, please
read our “Leasing Commercial Property from
your SIPP” for further details, a copy of which is
attached at Appendix 5.
Service charges
Any service charge that forms part of the lease
agreement will be administered by LSH.
Rent deposits
Should there be a requirement under the terms
of the lease for a rent deposit, the solicitor will
prepare the rent deposit deed and LSH will
arrange for the deposit to be held in an interest
bearing account.
Repayment of the rent deposit will be made at
the end of the term of the lease (or in accordance
with the terms of the lease), provided that the
tenant has complied with the terms of the lease.
Rent reviews
All rent reviews will be upwards only, and will
be carried out in accordance with the terms of
the lease:
■■ Connected Tenant
At the appropriate date, in accordance with
the terms of the lease, LSH will prepare a rental
valuation. LSH will communicate the results
to us, you, the member and the tenant and
prepare and obtain signatures on a Rent Review
Memorandum (RRM), following which the rent
will be invoiced at the revised amount.
■■ Unconnected Tenant
At the appropriate date, in accordance with the
terms of the lease, LSH will contact the tenant
to discuss the proposed revision to the current
rent. LSH will liaise with you, the member as
appropriate. Upon agreement LSH will prepare
and obtain signatures on an RRM, following
which the rent will be invoiced at the revised
amount.
■■ Should agreement not be reached with the
tenant, LSH will follow the terms of the lease
relating to the resolution of rent disputes.
Invoices
Any invoices relating to the property (which
could include business rates, refurbishment, and
insurance) will be forwarded to LSH who will
assess these for payment.
If LSH conclude that the invoice is a legitimate
expense of the landlord, it will request funds from
us and pay the invoice. If the tenant is liable to
reimburse the landlord for payment, LSH will deal
with the reimbursement.
Development work
If you intend to do any development work to the
property you need to consider whether there are
any ‘trading’ issues.
■■ Development work
This should be supervised by an architect or
building surveyor. We would require details of
the proposed building works and costs. The
developer and architect should provide legal
warranties to the SIPP confirming the work
they are doing, the standards and time-scales
involved, as well as details of their insurance
cover. The architect or supervisor must confirm
that the work has been completed to a certain
stage and will advise that a stage payment can
be made.
Trading income and gain is declarable to HMRC,
with tax due.
Maintenance of the property
For example, buying land, enhancing it by
obtaining planning permission and selling
on quickly could be construed as trading by
HMRC. This is more likely if the activity mirrors
your personal business (for example you are a
property developer) or you buy and sell on a
regular basis.
Where dealing with maintenance of the property
under the terms of a lease, the first consideration
is always whether the works proposed are the
responsibility of the landlord or the tenant. We
would be advised by LSH here. Where landlord’s
work, we would expect you to clear any work in
advance with LSH.
We cannot provide tax advice and recommend
you obtain such advice if you are in any doubt.
The SIPP can only pay for work that is landlord’s
responsibility and must be cleared with LSH in
advance. Please note that we must appoint the
contractor, and pay them directly. You must
also not take any commission or fee from the
contractor.
There are also the following further
considerations:
Arm’s length contractor
We expect the proposed contractors to be
unconnected to you.
■■
Asbestos
Where work is being done on a property we
must ensure that an asbestos survey has been
carried out and we have the findings of that
survey. Where asbestos is confirmed as being
present prior to the commencement of the work
we must have a copy of the Management Plan
and confirmation that any contractors working
on site have received a copy of this plan.
■■
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Costs
The capital costs of any development,
improvement or modification of property held
by the SIPP must be paid by the SIPP and carried
out by an unconnected party. We would expect
that capital costs paid by the SIPP be reflected
in an uplift in the market rent paid by the tenant
and we will require an independent valuation for
this.
■■
9
Part 5 Joint ownership and property sales
Joint ownership
Property sale
It is possible for your SIPP to jointly hold property
with other SIPP members, or with parties outside
the SIPP (including you or your business).
LSH will deal with all property sales.
However, there are a number of considerations
and conditions:
Co-ownership agreement
A co-ownership agreement must be agreed
and signed by all parties. This should outline
who is responsible for what, how decisions are
made and managed and outline the procedure
when one party wishes to sell or retire (or dies).
The solicitor dealing with the purchase will be
instructed to agree this before completion.
■■
Co-owner’s borrowing
Where the co-owner is borrowing (or has already
borrowed) to buy the property, there must not
be any outstanding loan secured on the property
on completion (or if there is, the lender has
agreed to limit their recourse to the share owned
by that co-owner so that the bank could not
look to the other owner to meet any debt. This is
often referred to as a ‘non-recourse’ loan.
■■
If the co-owner’s loan is effectively secured
against the SIPP’s interest, it would be viewed as
SIPP borrowing under tax rules (subject to the
overall limit) or, where the co-owner is you or a
connected party, an effective transfer of value
to you as it prejudices the value of your SIPP’s
interest. We will ask the solicitor to check on this
before completion.
SIPP borrowing
Where a number of our SIPP members are
buying a property together and are jointly
borrowing from a bank, then all those SIPPs
will be jointly liable for that loan. As such, if you
maintain payments but your co-owners do not,
your share of the property could be at risk.
■■
Managing agent
We would normally require a managing agent
to be appointed to manage the property where
there is co-ownership with a party outside the
SIPP.
■■
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10
LSH will notify the solicitor who will prepare the
appropriate documentation for signature by us.
Upon completion of the sale, the proceeds
will be banked in the member’s pension bank
account.
LSH will notify the tenants (if applicable) that we
are no longer the landlord and that rent standing
orders payable to LSH should be cancelled.
Insurance on the property will be cancelled
by LSH.
Should there be a loan in place, the solicitor
dealing with the sale will contact the lender
to obtain the redemption amount and this will
be settled from the proceeds of sale on the
date of completion. The legal charge will then
be removed.
Where we are selling to you or a party connected
to you we will require the sale price and terms
to be supported by an independent open market
property valuation carried out by a member
of RICS..
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11
MC Trustees
(PENSIONS) LIMITED
If you would like a copy of this document in larger print,
please contact us on 01675 444 600.
The SIPPs operated by MC Trustees (Pensions) Limited are the MC Trustees Private Pension
(incorporating the Simple SIPP) and the MC Trustees Self Invested Pension.
Tel: 01675 444 600
Fax: 01675 444 601
Email: [email protected]
Website: www.mctrustees.co.uk
MC Trustees (Pensions) Limited is registered in England at
Enterprise House, Meadow Drive, Hampton in Arden, West Midlands B92 0BD.
Co Reg No 05575694
MC Trustees (Pensions) Limited is authorised and regulated by the Financial Conduct Authority
(Firm Reference Number 461226) to establish, operate and wind up personal pensions.
Version 3 March 2014

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