Being a corporation tax professional myself, I must admit it took me a while to get my head around the mechanics of income tax relief in this case.
For what it's worth, I have pulled together a spreadsheet showing tax calcs for three different scenarios (net pay, relief at source and no relief at source). Hopefully, it would save time to folks in the future.
Assumptions:
Total income (prior to pension relief) 135,000
Gross contribution under net pay or claim method 35,000
Equivalent net contribution under relief at source (RAS) 28,000 (ie the contribution under RAS is assumed to be lower that for other two scenarios for comparability purposes)
Basic tax relief under RAS (claimed by provider) 7,000
SCENARIO 1. Salary sacrifice (net pay) - s193 FA04
Total taxable pay (net income) is 100,000 as the contribution reduces net income (s193(2) FA2004)
Upper limit Income Rate Tax
Personal allowance 12,570 12,570 0% -
Basic rate band 50,270 37,700 20% 7,540
Higher rate band 125,140 49,730 40% 19,892
Additional rate band N/A - 45% -
TOTAL 100,000 27,432
Take-home pay + pension fund (ignoring NIC) 107,568
There is nothing additional to include in SATR as all of the tax relief has been given through salary sacrifice (s193(8) FA04).
SCENARIO 2. Relief at source - s192 FA04
Total taxable pay (net income) is 135,000 as the contribution (grossed up by 20%) increases the basic rate and higher rate limits (s10(6)(b) ITA07 and s192(4) FA04) and also reduces "adjusted net income" (s58 ITA07) to £100,000, such that personal allowance (s35 ITA07) is fully reclaimed. The grossed up amount of contribution (C x 1.25) ie 28,000 x 1.25 = 35,000 should be included in box 1 (payments to PPRs where basic tax relief claimed by provider).
Upper limit Income Rate Tax
Personal allowance 12,570 12,570 0% -
Basic rate band 85,270 72,700 20% 14,540
Higher rate band 160,140 49,730 40% 19,892
Additional rate band N/A - 45% -
TOTAL 135,000 34,432
Take-home pay + pension fund (ignoring NIC) 107,568
SCENARIO 3. Relief on making a claim - s194 FA04
Total taxable pay (net income) is 100,000 as the contribution reduces net income ("Step 2" in s23 ITA07, s24(1)(a) ITA07). The actual amount of the contribution (ie no gross up for tax) should be included in box 2 (payments to RAR where no basic tax relief claimed by provider).
Upper limit Income Rate Tax
Personal allowance 12,570 12,570 0% -
Basic rate band 50,270 37,700 20% 7,540
Higher rate band 125,140 49,730 40% 19,892
Additional rate band N/A - 45% -
TOTAL 100,000 27,432
Take-home pay + pension fund (ignoring NIC) 107,568
As one can see, the three scenarios result in the same amount of home-take pay and pension pot increase. The higher amount of tax paid in scenario 2 is offset by the lower amount of the cash pension contribution (ie effectively HMRC just passes on the additional tax to the pension provider).
HMRC could have made this easier for us surely!