Michael McGrath (Cork South Central, Fianna Fail)
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The changes that were introduced in 2013 still apply. In 2013, it was deemed that this was a form of tax planning which allowed PRSA holders to pass large funds on to their spouse, civil partner or dependants with favourable tax consequences. In order to address this where a fund has not commenced benefits and the PRSA holder reaches an upper age limit of 75, the fund is deemed to vest, at which point three things happen. First, the fund is considered a benefit crystallisation event for the purposes of the SFT. Second, the imputed distribution regime applies to the fund with a notional annual distribution occurring. The third one, which was that the PRSA holder was locked out, will no longer be the case now because at 75 there is still a benefit crystallisation event, but access to the fund is permitted.