Which factor relating to his circumstances confirms that he will avoid incurring a special annual allowance charge in the current tax year?

Trevor is a member of a defined benefit company pension scheme. Which factor relating to his circumstances confirms that he will avoid incurring a special annual allowance charge in the current tax year?
A. He is a member of an Employer Financed Retirement Benefit Scheme (EFRBS)
B. He is aged 61
C. His total annual earnings have never exceeded £110,000
D. His benefits include the maximum level of death benefit

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