The effect of the abolition of substantial tax relief on dividends that pension funds received on their investments

[Alaric]

The system was in place to encourage companies to distribute, they would pay CT whether they had or had not paid dividends and if company went a few years without paying divs when they later did you could have surplus ACT that could not easily be relieved. You could get the position of ACT paid out greater than CT due, in which case the ACT often got carried forward and used in interesting ways that these days I cannot remember. (somewhere I have a handy textbook with all this explained and worked examples with interaction of losses, ACT, carry forwards etc)

Was it not also possible for the amount reclaimed by pension funds and other gross investors to equal or exceed the ACT and Corporation Tax actually paid? That may have applied particularly to "special" dividends that were in essence a return of capital.

[Sacky]

A bit late to the party but I came across this thread following (also belatedly) reading a Telegraph article on Gordon Brown's tax raid.
https://www.telegraph.co.uk/money/pensions/gordon-brown-ruined-retirement-generation/

The IFS said this in its 2014 Green Budget report...
At the moment, the personal tax system does not compensate pensions saving either for the tax paid on the normal return at the corporate level or for the presence of stamp duties. But versions of both forms of compensation have existed in the past. Prior to April 1993, repayable dividend tax credits on UK (not global) shareholdings were paid at a rate equal to the basic rate of income tax (which in 1992–93 was 25%). This was reduced by the then Chancellor Norman Lamont(now Lord Lamont) to 20% in his Spring 1993 Budget, and then abolished completely by Mr Brown in his first Budget in July 1997.
The March 1993 Budget measure is scored by the Treasury as boosting revenues in 1995–96 by an estimated £900 million. The July 1997 Budget measure is scored as increasing revenues in 1999–2000 by £5.4 billion. The latter is often described as a £5 billion pensions ‘raid’. However, only £3.5 billion of the £5.4 billion came from pension funds, with the remainder coming from other exempt taxpayers such as charities. In addition, the
concurrent cut in the main corporate tax rate from 33% to 31%, and a further cut to 30% in 1999, would have boosted the incomes of pension funds by up to £1 billion, reducing the net cost to pension funds to £2.5 billion or less.

Gordon Brown's Budget speech from 1997 is here and worth a skim. Eg, he mentions not wanting to push ahead with the 'previous Government's proposals to phase out tax relief on employee pension contributions'. Tax raid anyone?
https://api.parliament.uk/historic-hansard/commons/1997/jul/02/budget-statement

I wonder if anyone can remember this... "In addition, in his March 2001 Budget, Mr Brown introduced ‘individual pension accounts’, which were exempt from stamp duty on share transactions. However, these accounts never became widely available, with reports
suggesting that they were only offered by one provider."