- Understand the three main structures available to reduce Corporation Tax
- Review how pension contributions provide Corporation Tax relief (within HMRC limits)
- Learn how Family Investment Companies and combined strategies work
Each structure operates through a different mechanism and serves different strategic objectives. A SSAS reduces Corporation Tax through qualifying employer contributions whilst providing control over pension investments including commercial property. A Family Investment Company moves profits into a separate protected structure where assets can grow and be transferred to beneficiaries efficiently. The Lifetime Business Tax Plan combines both structures to deliver comprehensive tax efficiency across Corporation Tax, income extraction, and inheritance planning.
Below you will find detailed explanations of how each structure works, the circumstances in which each is most appropriate, and the compliance requirements that apply. These are established planning tools used by profitable limited companies throughout the United Kingdom. When structured correctly and operated within HMRC rules, they provide legitimate and effective solutions to the Corporation Tax burden that limited company directors face on retained profits.
Limited company directors face a Corporation Tax problem that employees do not encounter. When a company generates profit, that profit is subject to Corporation Tax before the director can access it personally. Any subsequent extraction through salary or dividends creates further income tax and National Insurance liabilities.
This creates a compounding tax burden that significantly erodes retained profits. Directors with annual profits between £50,000 and £250,000 or more are particularly affected. Traditional pension contributions offer one route to Corporation Tax reduction, but lack flexibility. Property investment through personal ownership attracts Capital Gains Tax and offers no Corporation Tax relief. The structures outlined on this page address these specific challenges through different mechanisms tailored to different circumstances and objectives.
A SSAS pension allows the limited company to make employer contributions that qualify for Corporation Tax relief. These contributions reduce taxable profits in the year they are made. The SSAS itself is a tax-exempt environment where investments can grow without Capital Gains Tax or income tax on returns. Directors retain control over investment decisions including the ability to invest in commercial property and make loans back to the sponsoring company under strict HMRC conditions.
A Family Investment Company is a separate limited company structure into which business profits can be moved through legitimate mechanisms. Assets held within the FIC can be invested and grown. Shares in the FIC can be structured to benefit family members and future generations whilst keeping control with the founding director. This structure addresses inheritance tax planning and protects accumulated wealth outside the trading company.
SSAS loanback: HMRC rules and conditions
SSAS pensions are regulated by The Pensions Regulator and must operate within defined HMRC rules. Family Investment Companies must be established and operated as genuine companies with proper governance. When a SSAS makes a loan to a sponsoring company, specific conditions apply:
- The loan term cannot exceed five years
- Interest must be charged at a minimum of one percent above the average base lending rate
- The loan must be secured by a first charge against assets of equal or greater value than the loan plus interest
- The loan cannot exceed fifty percent of the net value of the SSAS assets
- Repayment must be made in equal annual instalments over the loan term
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