Important information for AHCPS members nearing retirement If you are nearing retirement and your gratuity under the Superannuation Scheme is likely to be less than the maximum allowed under Revenue rules because you: Have received a reduction in salary over the last few years, even if you have full service (see next page for explanation) and/or Are short service and/or Have non-pensionable earnings there is a special tax break under Revenue rules that you might be able to take advantage of before you retire. This is known as a Last Minute AVC. The benefits of investing in a Last Minute AVC include: receiving a refund of tax on pension contributions maximising your tax-free cash lump sum at retirement. What is a Last Minute AVC? A Last Minute AVC is an excellent way of funding any shortfall between the tax-free cash lump sum provided for within the Superannuation Scheme and the maximum Revenue approved tax-free cash entitlement. The benefits of investing in a Last Minute AVC include: Receiving a refund of tax on pension contributions Maximising your tax-free cash lump sum at retirement. How does it work? A single investment in an AVC is made prior to retirement. Following retirement, you get back your initial investment, less charges; and you also receive a tax rebate direct from Revenue. It is your own responsibility to claim the rebate from Revenue. The tax reliefs available are those currently applying, and the value of these tax reliefs apply directly to you. Because this is a short-term investment, it will not provide an investment return. How do I know if I am eligible? Following a consultation with a Cornmarket Financial Consultant, they will establish the maximum tax rebate available to you. It is possible to use up any unused allowance for 2012 in addition to 2013. Your salary, service, age and tax band are a few of the factors which must be considered in establishing your eligibility. IMPORTANT If you have had a reduction in your salary over the last few years there is a very good chance that a Last Minute AVC makes sense for you. One of the reasons for this is because the calculation of final salary at retirement under Revenue rules differs from the calculation of your salary at retirement under your employers Superannuation Scheme rules (please see example on next page). Please contact Cornmarket on (01) 408 4058 to set up an appointment so you can establish your eligibility for a Last Minute AVC taking into account your service, salary, tax rate etc. If a Last Minute AVC is appropriate, we will guide you through the various steps involved. You can t do a Last Minute AVC after retirement so please ensure you get in touch in advance of retirement. Warning: The value of your investment may go down as well as up. Warning: Past performance is not a reliable guide to future performance. Warning: This product may be affected by changes in currency exchange rates.
Last Minute AVCs to take into account the reduction in Public Sector Pay The basis for a Last Minute AVC for an individual, including those with full service, is that the calculation of Final Salary (Remuneration) under Revenue pension rules may differ from the Final Pensionable Salary used in the calculation of Superannuation benefits. If your Final Salary under Revenue pension rules is higher than the Final Salary used by the Superannuation Scheme there may be a substantial tax benefit to you in using an AVC policy to increase your retirement lump sum. For example, individuals who are retiring in 2013 may have their maximum retirement lump sum calculated using their basic salary earned in 2009, plus the average of any fluctuating payments over three or more years up to then. The full definition of Final Salary (Remuneration) under Revenue Rules may be found in Appendix 1. EXAMPLE: Last Minute AVC for Assistant Principals and Principal Officers: In the examples below, the Tax Relief reflects the amount of income tax the individual would receive back from the Revenue Commissioners based on the assumptions set out in the notes on the next page. Example A would receive back 6,655, Example B, 4,976 and Example C, 12,739. Client Scenario Example A* Example B** Example C*** Retirement Date (normal retirement age or later) 31/07/2013 31/07/2013 31/07/2013 Final Pensionable Salary 76,768 (LSI 2) 76,768 (LSI 2) 76,768 (LSI 2) Service 40 years 40 years 35 years Salary in December 2009 82,520 (LSI 2) 80,016 (LSI 1) 82,520 (LSI 2) Salary with CPI (Consumer Price Indexed) applied = 87,265 pa 84,617 pa 87,265 pa Revenue Maximum Salary The Calculation Revenue Maximum Gratuity Revenue Maximum salary 130,897 126,925 130,897 x 1.5 (CPI applied) Gratuity received Final Pensionable Salary x 1.5 (or years x 3/80 if less than 115,152 115,152 100,758 40 years service) Last Minute AVC Scope (Revenue Maximum Gratuity 15,745 11,773 30,139 less Gratuity received) Last Minute AVC plus 3% contribution charge 16,232 12,137 31,071 Tax Relief Received (assuming tax relief @ 41%) 6,655 4,976 12,739 AVC returned after retirement 15,745 11,773 30,139 Plus Tax Relief 6,655 4,976 12,739 Total received 22,400 16,749 42,878 Notes 1. *Example A assumes Assistant Principal Standard Scale (Modified PRSI) with no increment since December 2009. The same principle applies to all other grades, but with different figures applying. 2. **Example B assumes Assistant Principal Standard Scale (Modified PRSI) with 1 increment since December 2009 (from LSI 1 to LSI 2). The same principle applies to all grades, but with different figures applying. 3. ***Example C assumes Assistant Principal Standard Scale (Modified PRSI) with no increment since December 2009, but 5 years short of full service at NRA. The same principle applies to all other grades, but with different figures applying. Please see next page for more notes on the examples above.
Notes relating to examples on previous page 4. The examples assume a 3% contribution charge on your last minute AVC when transacted with Cornmarket Group Financial Services Ltd. 5. A Management Charge will also be charged by Irish Life. This is a % of the value of the fund and will be charged as long as the fund is invested in your AVC. Typical management charge is 1% per annum and it is charged pro rata. 6. We have also assumed that you can claim 41% tax relief on all your AVC contributions. This, of course, may not be the case and we advise you to receive appropriate tax advice before completing a last minute AVC. 7. Finance Act 2011 introduced a 0.6% pension levy on the market value of pension funds including AVCs. The 2013 levy will be calculated as at 30 June 2013 so if you have an AVC in place at that time you will be liable for the levy which will be deducted automatically from your AVC fund by Irish Life. 8. You make a last minute AVC payment to make up the full shortfall shown for the maximum Gratuity. If I do a last minute AVC with Cornmarket, where is it invested? Most last minute AVC business transacted with Cornmarket Group Financial Services Ltd. is invested in either the Cash Fund or the Capital Protection Fund through Irish Life. However, you are free to invest your money in over 20 different funds. Cash Fund This is a very low risk fund. While there will be a very low level of volatility in fund returns, there is also only a very low potential for gains. You should be aware that it can also fall in value. It is suitable for investors who are very close to retirement or have a very low appetite for risk. Capital Protection Fund This is an actively managed smoothed fund. The fund aims to give investors the benefits of some equity participation while at the same time ensuring that the value of the fund will not fall. The majority of the fund is invested in cash deposits and bonds. It is suitable for investors who are close to retirement or have a low appetite for risk. Please see Appendix 2: Overview of Irish Life regarding the security of their assets. Warning: The value of your investment may go down as well as up. Warning: Past performance is not a reliable guide to future performance. Warning: This product may be affected by changes in currency exchange rates.
APPENDIX 1: Revenue Commissioners guideline notes. April 2005 Final Remuneration may be computed on one of the following bases: 1. (a) Basic remuneration over any twelve month period of the five years preceding the relevant date (i.e. the date of retirement, leaving service or death, as the case may be) PLUS (b) The average of any fluctuating emoluments over three or more consecutive years ending on the last day used in (a) above. 2. The average of the total emoluments for any three or more consecutive years ending not earlier than 10 years before the relevant date. 3. The rate of basic pay at the relevant date or at any date within the year ending on that date plus the average of any fluctuating emoluments calculated as in (1) above. Provided that Basis (3) cannot be used where within three years before the relevant date an employee: a) Was promoted or received a special increase in basic pay, and b) The total increase over the relevant three year period is greater than it would have been if the remuneration on the day of commencement of the period had been increased proportionately to the increase in the Consumer Price Index, or to increase applicable to the employment under a National Wage Agreement, during the same three year period. However, it is possible to agree beforehand with Revenue that such increases, if given on a recognised scale applicable to defined groups of arm s-length employees, will not prevent the availability of basis (3). Whenever final remuneration is calculated by reference to a year or years other than the 12 months ending with the relevant date, each such year s remuneration may be increased in proportion to the increase in the cost of living from the last day of that year up to the relevant date referred to as dynamised final remuneration. This also applies to fluctuating emoluments so that fluctuating emoluments of a year other than the twelve months ending with the relevant date may be increased as detailed above. Where sick pay is drawn for 10 or more years (under, say, a sick pay or permanent health insurance scheme) and the member is regarded as continuing in service, final remuneration may be calculated by reference to the employee s pay for a selected period as detailed above before the date on which he dropped from full pay to sick pay. This figure may be increased proportionately to increases in the Consumer Price Index between the relevant dates.
APPENDIX 2: Overview of Irish Life regarding the security of their assets This note outlines the up-to-date position with regard to the security of assets held with Irish Life Assurance Company as at the 31st December 2012. Security of Assets To provide a comprehensive overview of security of assets, Irish Life will address 4 separate areas: 1. Corporate Structures and the ring fencing of assets and liabilities. 2. The value of policyholders liabilities and the level of surplus assets. 3. Irish Life s low risk approach to ensuring policyholders security. 4. Irish Life s low risk approach to managing investment risk. 1. Corporate Structures and Ring Fencing of Assets and Liabilities Irish Life Group Limited is the parent of both Irish Life Assurance Company ( ILA ) and Irish Life Investment Managers Limited (ILIM). ILA pools the unit-linked assets managed by ILIM in its Life Assurance fund (the Fund). ILA has consistently generated significant levels of capital. It has never required capital support from its parent company and does not envisage requiring any external capital support in the future. ILA is authorised and regulated by the Central Bank of Ireland (the Regulator), and is subject to extensive regulations which are primarily designed to ensure that policyholder benefits are safeguarded. Policyholders assets held in ILA are legally ring-fenced from other activities of Irish Life Group Limited and from other companies within the group. The assets within the Fund may not be transferred or applied for any purpose other than the policyholders in the Life Fund. For example, the Life Fund cannot be subjected to any mortgages, charges or liens relating to the other businesses of the group. The policyholders of ILA have priority over other creditors of ILA. Subject to strict conditions, certain excess assets may be distributed as dividends from ILA to its parent company. All figures quoted in this note are after allowing for any such dividend payments. The detail of the supervisory and legal framework, and the solvency margin requirements, are contained in the Insurance Act 1989 and various EU Directives which address the regulation of the Life Fund. 2. Valuing Policyholder Liabilities and Surplus Assets The value of liabilities and the level of solvency margin cover within ILA were calculated as at 31/12/2012: Total Unit-Linked liabilities (92% of liabilities): 24.8bn Total Non-Linked liabilities (8% of liabilities): 2.1bn Total Policyholder liabilities: 26.9bn Required Solvency margin: 416m Surplus (excess over solvency margin): 367m Free Assets (excess assets over liabilities): 783m Free Assets cover of the required solvency margin: 1.88 times. ILA s solvency cover has increased from the 175% cover at the end of 2011 to 188% at the end of 2012. The business generated surpluses which have led to an improved regulatory capital position. The company s target solvency cover remains at 175%. Fluctuations in the solvency cover can occur over the short-term, but over a medium-term horizon the capital position is strongly supported by the profitable book of business that ILA has written. Short-term falls are possible due to, for example, falls in stock markets. No such falls happened during the first half of 2012 and hence the main driver of the increase in the solvency cover was the expected surpluses on the existing book of business. The value of liabilities is calculated in line with regulations which require a prudent approach to be used. This means that the value of the liabilities shown above is greater than a best estimate of the liability amount. The level of free assets would be significantly higher if a best estimate approach was used to quantify the value of the liabilities. This prudent approach provides significant additional security for policyholders. The free assets are valued according to prudent regulations which place a lower value on certain asset types than normal accounting conventions. For example, no value is placed on intangible assets and fixed assets are depreciated more quickly than under other accounting standards. Without these additional restrictions, the value of the free assets would be further enhanced. ILA s financial strength has been demonstrated by its ability to maintain its high solvency margin cover ratio during the recent turbulent financial conditions, and by its ability to pay dividends to its parent company. ILA also has the flexibility to use its VIF asset as collateral to secure additional regulatory capital from international markets, should the need ever arise in the future.
3. Low Risk Approach to ensuring Policyholders Security Policyholders in the Life Fund benefit from a very low risk philosophy with respect to accepting risk and the management of risk in ILA. The company has a strong risk governance structure and has invested heavily in risk management. Limits have been set by the Board in respect of the allowable level of risks for all of the material risks that ILA is exposed to. Examples of this low risk approach include: The vast majority of liabilities are unit-linked where the investment risk is passed to policyholders. Matching assets are held in respect of all unit-linked liabilities ILA holds fixed interest (mainly French, German, Irish and other EU government bonds) and cash assets to back the non-linked liabilities. These assets generate cash-flows which match the future payments ILA will make to non-linked policyholders A significant portion of non-linked liabilities are reassured, including a large proportion of the Irish Life protection business and the bulk of the ILA annuity book A substantial amount of re-assurance assets are held in trust to collateralise the reassurers obligations to ILA. In light of the low risk profile and strong risk culture, the target Free Asset Cover ratio of 1.88 times the required solvency margin offers a very high level of security to policyholders. 4. Managing Investment Risk ILA has a low risk approach to investment risk. As noted above, matching assets are held in respect of all unit-linked liabilities. Fixed interest (mainly EU government bonds) and cash assets are held to back the non-linked liabilities. The cash assets are held across a range of international banks. 84% of the fixed interest assets are exposed to AAA rated counterparties (mainly French, German, Austrian, Dutch and Finnish sovereign bonds) and 11% are exposed to the Irish sovereign. (b) Schedule 7 of the Life regulations sets out restrictions on the maximum % of certain asset types that can be held to match non-linked technical reserves. These restrictions ensure that assets must be appropriately diversified. (c) When calculating the value of the policyholder liabilities, there are a series of mismatch tests required. These tests ensure that the assets will be sufficient to cover the policyholder liabilities even if investment conditions change in the future. (E.g. one mismatch tests involves a 25% drop in equities/property and a 0.5% reduction in yields.) This requirement means that if the policyholder liabilities are backed by unsuitable assets, then additional assets must be set aside. To summarise, Irish Life s risk philosophy is to minimise risk where possible and appropriate. This is achieved by: 1. Matching liabilities with appropriate assets. 2. Taking very little credit risk by investing mainly in Euro sovereign gilts and holding deposits with an international range of banks to back the non-linked liabilities. 3. Excess assets, excluding owner occupied property and some seed capital for linked funds, is invested in cash. The pooled approach achieved in the Life Fund has a number of advantages for our clients: Extremely tight tracking errors against underlying benchmarks Foreign withholding tax benefits Re-balancing at minimal cost Enhanced liquidity across different assets and asset classes Surplus reserves providing additional security against fraud etc. The regulations governing the investment of non-linked assets include the following restrictions: (a) Per Annex V of the 1994 Life Regulations only a certain list of assets are admissible per section 2 (2). ILA cannot write derivatives and can only purchase derivatives either for investment efficiency or to reduce market risks. It cannot take geared positions. Source: Irish Life Assurance plc, July 2013. Christchurch Square, Dublin 8. Tel: (01) 408 4000 Fax: (01) 408 4011 Cork Office. Tel: (021) 455 3335 Galway Office. Tel: (091) 562 727 E-mail: info@cornmarket.ie Website: www.cornmarket.ie A member of the Irish Life Group Ltd. Cornmarket Group Financial Services Ltd. is regulated by the Central Bank of Ireland. Irish Life Assurance plc is regulated by the Central Bank of Ireland. Telephone calls may be recorded for quality control and training purposes. 7689 AHCPS Last Minute AVC 06/13