13.5 Karen belongs to a number of registered pension schemes. Until tax year 2007-08 she had received no benefits from any of these schemes but in October 2007 she took a lump sum of £1,280,000 from one of her schemes. She received no further benefits until July 2010 when she took a lump sum of £400,000 from another of her schemes.

(a) Calculate the amount of any lifetime allowance charges arising in relation to either of Karen's lump sums.

(b) How would the situation change if the lump sum of £400,000 had been received in October 2007 and the lump sum of £1,280,000 had been received in July 2010?