Nikki Spoor
White Hart Associates
East House
109 South Worple Way 
London
SW14 8TN
										4 April 2007 

Dear Nikki,

THE GREEK LIMITED EXECUTIVE PENSION SCHEME

Many thanks for the enclosures for the Greek Limited.

I have sent to John and Andros the documentation to establish the Scheme. I have also arranged for The Greek Limited to act as Principal Employer. With regard to the participation of Reflexoak Limited, I confirm that the 2004 Finance Act does allow contributions to be paid to a SSAS from an investment company and obtain tax relief as allowable management expenses for the period in which the sums are paid. The provisio to “automatic” relief is the contribution being treated as an ordinary annual contribution; we can structure the payments to qualify as an ordinary annual contribution if necessary. The contributions can take various forms such as assets owned by Reflexoak and this may be desirable if there is insufficient cash and borrowing to purchase the property in full by the SSAS.

I have gone through the rules for the Nat West Scheme, I recommend that we adopt the subset of rules I sent to Andros and John as the Nat West scheme rules do not seem particularly flexible. For example, they do not provide for a general fund in the scheme. This is important, since the creation of a general fund will assist the members with inheritance tax planning in future years and also allows contributions to be paid to the scheme without the requirement at outset to state in whose favour the payments should be allocated. There will be a notional allocation of the Scheme’s assets under the new Scheme to safeguard any fall out between John and Andros down the line, but if we put something in that is binding now (as the NatWest rules are written) we could be faced with a tax consequence down the line if John and Andros ever wanted to re-allocate the funds. 

Perhaps you would let me know if you wish to bring in Reflexoak, in the meantime I will await from Andros and John the completion of the paperwork. 

Kind regards

Yours sincerely

Gavin McCloskey
For Pensionpractitioner.com