In April's Budget the Chancellor introduced certain anti-forestalling measures designed to prevent individuals from front-end loading their pension contributions in anticipation of the 2011 restrictions. For more details of these measures, please see our earlier bulletin here .
In the Pre-Budget report, the Chancellor announced that the income threshold which triggers the application of the anti-forestalling requirements will be reduced to reflect the new £130,000 threshold for post-April 2011. This means that individuals with a pre-tax income of £130,000 or more in the current tax year, or in either of the previous two tax years, and who increase their pension savings beyond their normal, regular pattern on or after 9 December 2009, will find that increase tested against the special annual allowance (either £20,000 or £30,000) and the excess subject to the special annual allowance charge. Those who are already subject to the anti-forestalling measures (because their taxable income is £150,000 or more) will be unaffected by the change.
The Government has also confirmed that the special annual allowance tax charge will be set at the "appropriate rate". This will allow the rate to increase next year (from 20% to 30%) to reflect the new top rate of income tax.