I have had some cause recently to consider the position of those fortunate enough to be earning £150,000 or more.

After putting aside all thoughts of jealousy, it began to occur to me that maybe there are some downsides to having very large…er…assets!

The Government has of course already announced a new 50% tax rate for high earners, heralding the departure from these shores of various D list celebrities for which my sympathy rating is Zero

However, recent research by yours truly – OK in reality consisting of me chatting to several very knowledgable consultants at the recent excellent Professional Pensions Show – has revealed that there are already some very highly inventive ways to allow high earners to limit payment of what to many seems a punitive rate of tax.

A great deal of talent which is of significant benefit to UK PLC and, for the more venal amongst us, tax is likely to be lost to the Treasury by those individuals ‘offshoring’ in some way. And its not only the rate of tax that’s an issue. Couple that with a gradual reduction in Personal Allowances for those with taxable incomes of £100,000 or more from April 2010 and you have for some, a marginal tax rate of 60%. No wonder foreign climes seem attractive and not just for footballers and their WAGS.

But for those who choose (or have) to stay, what options exist for them to make the most of their income? A few years ago, when pension contributions were subject to the statutory Earnings Cap, many high earners were offered membership of ‘top up’ arrangements by their employers.

These EFRBS (Employer Financed Retirement Benefit Schemes) were unapproved by the Revenue of the time. Being unapproved, they were of course outside the Cap Limits. Obviously, there was no tax relief on contributions going in, but neverthelss they provided an attractive option.

When the Earnings Cap was removed under the 2006 ‘A Day’ tax simplifications, use of these EFRBS largely fell out of favour for those high earners who were nonetheless still within the Lifetime Allowance Limits or who had claimed certain ‘protections’.

But as the Governor of California might say “they’re back!!”. Lot’s of work then on the horizon for legal advice and consultancy …maybe I might need to start worrying about foreign lands myself…and then of course, pigs might fly!!