As practising IFAs, we have become increasingly concerned with this Government&#39s continuous changes and additions to pension legislation.

Since 1997, we have seen the abolition of ACT relief and the replacement of Serps which has increased the cost of retirement funding. We now have the introduction of stakeholder pensions, concurrency and the new investment instrument, the individual pensions account.

With an ageing population, we understand that the Government is keen to reduce the burden of state pensions and is introducing lower charged and flexible contracts which will now incorporate concurrency. The original intention was to encourage the lower-paid workforce to contribute to a stakeholder scheme which was never likely because of their limited disposable income and the lack of compulsion.

Now the Government is aiming stakeholders at middle-income earnings. Stakeholder, and the new IPA, increase the level of complexity, which is likely to increase the risk of getting things wrong.

We fear the end result will be considerable numbers deciding not to invest in pension at all and eventually compulsion will become necessary.

Concurrency will allow employees earning less than £30,000 per year to contribute to an occupational scheme and a stakeholder, combining what has been separate pension regimes. By doing so, it will enable the participants to take 1.5 times salary as tax-free cash from the occupational scheme and 25 per cent from Stakeholder. Surely this runs counter to the Government&#39s aim to increase its tax receipt?

Instead of concurrency, why not impose stakeholder terms on existing AVCs and FSAVCs and revert to the pre-1987 rules for AVCs? This would give low-cost, flexible terms for topping up occupational schemes and also remove a layer of confusion.

IPA is, in effect, a low-cost Sipp. The idea in principle is fine. However, there are several flaws in the Revenue press release dated July 11, 2000. It seems to be confusing the investment instrument (the IPA) with the stakeholder and its regulations.

Reading the case studies added to the confusion. The case study of Miss A seems to suggest a teacher would be better off with a stakeholder IPA rather than joining an index-linked final-salary occupational scheme.

While the stakeholder and the IPA are, in themselves, good concepts, the detail has been poorly drafted. If the purpose is to encourage more people to contribute to a pension, then the legislation should be simple and transparent.

Kay Lowe, Equal Partners, John Sheridan, Vivienne Starkey, Eddie Titcomb, Haddock Porter Williams