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Corrected the STBM pension comparison page (`docs/book/programs/gov/hmrc/pensions-comparison-stbm.md`): STBM raises the basic-rate limit and every limit above it for non-savings income, and every savings and dividend limit, rather than widening every band, its basic amount is £10,000 in its 2023-24 to 2026-27 systems, Microcosm UK imputes employer contributions from the same ONS ASHE table (P10) as STBM, PolicyEngine UK now estimates carry-forward of unused annual allowance from 2020-21, the threshold income test has been £200,000 since 2020-21, and salary sacrifice under arrangements made before 9 July 2015 can be supplied.
47 changes: 33 additions & 14 deletions docs/book/programs/gov/hmrc/pensions-comparison-stbm.md
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Expand Up @@ -20,23 +20,36 @@ more detail on the PolicyEngine side.

| | PolicyEngine UK | STBM |
|---|---|---|
| How relief is given | Reduces taxable income by the contribution (`pension_contributions_relief`) | Treats contributions as paid net of basic rate: grosses them up by 1/(1 − basic rate) and widens every rate band above the starting band by the gross amount, as under relief at source |
| How relief is given | Reduces taxable income by the contribution (`pension_contributions_relief`) | Treats contributions as paid net of basic rate: grosses them up by 1/(1 − basic rate) and raises the basic-rate limit and every rate limit above it by the gross amount, as under relief at source. For savings and dividend income it raises every limit, including the starting-rate limit for savings and the top of the 0% dividend band (the dividend allowance), neither of which relief at source raises |
| Contributions that get relief | The person's own contributions | Employee contributions, additional voluntary contributions **and employer contributions** |
| Basic-rate relief added to the pot | Not shown separately | Recorded separately (`pension_relief_at_source`) |
| Earnings limit | Relief capped at relevant UK earnings: employment income, employer-paid Statutory Sick Pay and Statutory Maternity Pay, and self-employment profit | No earnings cap; £3,600 limit when total income is below it |
| Earnings limit | Relief capped at relevant UK earnings (employment income, employer-paid Statutory Sick Pay and Statutory Maternity Pay, and self-employment profit), or £3,600 for relief-at-source contributions if earnings are lower | No earnings cap; when total income is below a basic-amount parameter the limit is that amount (£10,000 in its 2023-24 to 2026-27 systems, £3,600 before) |
| Annual allowance | £60,000 (`pension_annual_allowance`), tapered only when adjusted income is above £260,000 and threshold income is above £200,000, as in FA 2004 s. 228ZA | Tapered on total income above a threshold-income parameter |
| Contributions above the allowance | Annual allowance charge on the excess, taxed as the top slice of income (`personal_pension_contributions_tax`) | Relief stops at the allowance; no separate charge |
| Employer contributions in the data | Read from the data (`employer_pension_contributions`) | Imputed when missing from the FRS, using the ONS ASHE employer-contribution bands (`src/Pensions.jl`) |
| Carry-forward of unused allowance | Input `unused_pension_annual_allowance` (FA 2004 s. 228A) adds to the allowance; defaults to nil, as the survey data has no past pension input amounts | Not modelled |
| Employer contributions in the data | An input (`employer_pension_contributions`). Microcosm UK draws it from the ONS ASHE employer-contribution bands (Table P10); the Enhanced FRS sets it to three times employee contributions for survey respondents and imputes it with a quantile regression forest on the high-income records whose incomes it imputes from the SPI | Imputed when missing from the FRS, using the ONS ASHE employer-contribution bands (`src/Pensions.jl`) |
| Carry-forward of unused allowance | `unused_pension_annual_allowance` (FA 2004 s. 228A) adds to the allowance. As the survey data has no past pension input amounts, from 2020-21 the default estimates it from an assumed five-year history (this year's input and taper incomes deflated by average earnings growth); before 2020-21 it is nil | Not modelled |

The STBM column describes its Scottish systems, its default. In its
rest-of-UK systems from 2023-24, `non_savings_basic_rate` points at the 40%
rate (`params/sys_2023_24_ruk.jl` onwards), so there the gross-up uses 40%
and, for non-savings income, only the higher rate limit (£125,140, where the
additional rate starts) rises, not the basic-rate limit. In every system all
savings and dividend limits rise.

## Where the two models differ

### 1. Reducing taxable income versus widening the bands

For an income-tax payer whose contribution stays inside one band, the two
methods give the same total relief. They can differ when the person pays
little or no income tax: STBM still records the basic-rate addition to the
pot, which PolicyEngine UK does not show.
In STBM's Scottish systems, for an income-tax payer with only non-savings
income whose contribution stays inside one band above the Scottish starter
rate, the two methods give the same total relief. They can differ when the
person pays little or no income tax: STBM still records the basic-rate
addition to the pot, which PolicyEngine UK does not show. They also differ
when dividends exceed the dividend allowance, because STBM widens the 0%
dividend band by the gross contribution and PolicyEngine UK does not.
Savings income in the starting-rate band does not make them differ: that
band shrinks as taxable non-savings income rises, so PolicyEngine UK's
deduction frees as much of it as STBM's higher starting-rate limit.

**The personal allowance taper.** In law, gross pension contributions
reduce adjusted net income
Expand All @@ -61,7 +74,7 @@ employee's bands further than the law does.
The legal taper
([FA 2004 s. 228ZA](https://www.legislation.gov.uk/ukpga/2004/12/section/228ZA))
uses "adjusted income", which adds employer contributions, and applies only
when "threshold income" is also above £200,000 (from 2023-24).
when "threshold income" is also above £200,000 (from 2020-21).

- PolicyEngine UK applies both tests
(`pension_annual_allowance_adjusted_income` and
Expand All @@ -70,8 +83,9 @@ when "threshold income" is also above £200,000 (from 2023-24).
income of £300,000 but threshold income of £200,000, so keeps the full
£60,000 allowance. Its limits: by default the pension input amount is
cash contributions, so defined-benefit accrual is counted only if supplied
as an input, and all salary sacrifice is treated as made on or after
9 July 2015.
as an input, and salary sacrifice is treated as made on or after
9 July 2015 unless `pension_contributions_via_salary_sacrifice_pre_2015` is
supplied.
- STBM tapers on total income above a threshold parameter.

Both affect only very high earners.
Expand All @@ -80,7 +94,11 @@ PolicyEngine UK does not model the money purchase annual allowance, the
£10,000 limit on money purchase savings after pensions are first flexibly
accessed
([FA 2004 s. 227ZA](https://www.legislation.gov.uk/ukpga/2004/12/section/227ZA)).
It always uses the default chargeable amount.
Its annual allowance charge is always on the default chargeable amount,
the pension input amount above the annual allowance (s. 227ZA(3)), never the
alternative chargeable amount (s. 227B), which replaces it when the money
purchase annual allowance is exceeded and the alternative amount is the
larger (s. 227ZA(1)).

### 4. Lifetime and lump sum allowances

Expand All @@ -92,8 +110,9 @@ are drawn, not to contributions.
## What neither model does

- Working out carry-forward of unused annual allowance from the previous
three years. PolicyEngine UK accepts the result as an input but does not
derive it from past years.
three years' actual pension input. PolicyEngine UK accepts it as an input
and otherwise estimates it from an assumed history, not from recorded past
years.
- Behavioural responses: contributions are held fixed when tax rates change.
- Decumulation: crystallisation, the tax-free lump sum, and annuity versus
drawdown choices.
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