An in-specie pension contribution is where an asset such as property or shares is transferred to a UK registered pension scheme and the value of that asset represents the amount of the pension contribution on which tax relief is claimed.  

These have long been a useful planning tool and the method of making an in-specie contribution has been set-out in the HMRC Pensions Tax Manual for the last fourteen years.  

However, in October 2016 tax relief on in-specie contributions to a number of SIPP products was challenged by HMRC which led to the firm SIPP Choice Ltd taking HMRC to court with a test case. In May 2018 the First Tier Tribunal found in favour of SIPP Choice. This ruling was subsequently appealed by HMRC in the Upper Tribunal and the outcome of the appeal was released yesterday in which the judge found in favour of HMRC.