Questão jurídica principal
Whether excessive pillar 3a contributions that were not reclaimed reduce the taxable amount of a later capital payout.
Decisão extraída
No. The entire pillar 3a capital payment remains taxable, even if part of the earlier contributions exceeded the deductible maximum and were not reclaimed.
Fundamentação extraída
The statutory scheme limits both deductibility and tax-favored treatment of pillar 3a contributions. Overpaid amounts must be reclaimed from the provider; pillar 3a accounts are not intended as savings accounts. Full taxation of the capital payment applies regardless of whether earlier contributions were fully deductible, especially where the taxpayer knowingly left the excess in place.