Looking wider it does appear that this is only likely to affect formal arrangements that have been established by larger employers. Where a company wants to offer choice to all employees there will be documented procedures in place and salary sacrifice is obvious. If there are informal discussions around the package for senior employees or within a small company these would not clearly be a salary sacrifice.
Overall the additional considerations may reduce the growth of new flexible benefit arrangements and some existing schemes may be simplified. Protection benefits for the employee serve an important function for the employer, their employees and families and the Government and should be treated like pensions under these proposals.
Alan Sparks, Canada Life Group Insurance