The High Court’s decision in the Lloyds Bank case:

  • requires schemes to equalise benefits earned in the period between 17 May 1990 and 05 April 1997 to correct for the inequalities of GMPs
  • approved a range of methods which could be adopted to achieve this requirement. However, given the complexity of the subject, the Lloyds Bank case couldn’t deal with all issues which can arise in an equalisation project.

In this context, HMRC has published two newsletters providing guidance on the tax issues relating to GMP equalisation.

Most schemes will want to implement GMP equalisation projects as soon as reasonably practicable. This Guidance has been prepared to help them do so in a proportionate and pragmatic way. It highlights tax issues which schemes may encounter in doing so, to enable schemes to make informed decisions and suggests possible approaches for dealing with those issues. Given the technical nature of certain tax-related issues, this Guidance may include more background information and analysis than some of the other guidance produced by the GMP Equalisation Working Group. Nevertheless, it’s been assumed readers will have a working knowledge of GMPs and why they can produce unequal benefits between male and female members.


Feb 2021 – GMPE Tax Guidance


Daniel Gerring – Chair (Travers Smith)

Mark Riordan (Capita)

Kathy Cruse (Willis Towers Watson)

John Wilson (Spence & Partners)

Richard Wyatt (Mercer)

Catherine McAllister (Addleshaw Goddard LLP)

Chris Widdison (Travers Smith LLP)

James Riley (Isio)

Rebecca Shevill (AXA)

Shayala McRae (Lane Clark & Peacock LLP)

Wendy Pitcher (Willis Towers Watson)