The calculations set out in the sections Calculation of the initial benefit offsets - member not in receipt of pension benefits (AFPS75, AFPS05, FTRS and RFPS), Calculation of the initial benefit offsets - tax charge attributable to AFPS15 - or member in receipt of pension benefits (all schemes) and Adjusting the initial benefit offsets when they are applied other than at age 65 of this guidance require a Relevant Date to be adopted. The MOD has provided guidance that should be used when calculating scheme pays offsets within AFPS. Our understanding of this advice is set out below, although the administrators should confirm with the MOD pensions policy team if this guidance is not clear or further clarification is required.

In the following paragraphs of this note the Relevant Date is determined differently depending on the timing of the Scheme Pays calculation relative to a member's date of retirement. In this context references to "retirement" should be interpreted as the date at which a member first begins to receive pension benefits from the relevant tax registered pension scheme. For the avoidance of doubt, this does not include benefits payable under Early Departure Payment legislation.

The Relevant Date will generally be the 5^th April at the end of the tax year which triggered the Annual Allowance charge.

However, where a member retires during a tax year, and requests that a scheme pays deduction is applied to their pension benefits from that date, then the Relevant Date is the retirement date.

Where a member is already in receipt of their pension benefits at the point at which they elect for Annual Allowance scheme pays, the Relevant Date will be the 5^th April at the end of the tax year which triggered the Annual Allowance charge.

We note that in the unlikely event that a member:

• retires during the PIP in which an Annual Allowance charge is incurred
• does not elect for Annual Allowance scheme pays prior to beginning to draw pension benefits
• but does then make an Annual Allowance scheme pays election for implementation prior to the end of the 5^th April following the PIP

further guidance on an appropriate Relevant Date should be sought from the MOD pensions policy team.

Where members incur multiple Annual Allowance charges, and then elect for Annual Allowance scheme pays on more than one occasion, the consequential benefits for each will be calculated separately. In this situation each scheme pays election would therefore be expected to have a different Relevant Date.