There will also be some schemes whose rules do not permit flexi-access drawdown. These individuals will only have the option of a lump sum.

Other BCEs 

If you have a client transferring their UK pensions to an overseas pension, there will still be an LTA test on those funds given they are leaving the UK tax environment. The test takes places regardless of the age of the client. 

There can no longer be an LTA charge on any LTA excess, but the provider will still conduct the test and report the usage to the client, as it would be relevant if the client still has uncrystallised funds in the UK from which they plan on taking a PCLS.

Technically speaking, a client can still take the excess as an LTA excess lump sum, which would now be subject to marginal rate, provided they are age 55 or above, but most clients would presumably transfer the whole fund to the qualifying recognised overseas pension scheme.

Serious ill-health lump sums are also affected by the change in rules. This is where a client has less than a year to live and takes their entire fund as a lump sum.

Previously the whole of the fund would have been paid free of income tax, although an LTA charge would have been paid on any excess over the LTA.

Now, the part of the fund up to LTA is tax-free, and income tax is chargeable on the excess over the LTA. 

Martin Jones is technical manager at AJ Bell