Delay in implementation of TRS under 5MLD

The 5th Anti-Money Laundering Directive (5MLD) extends the requirement to register on the Trust Registration Service (TRS) to many non-tax paying trusts that are currently excluded.  Following a regular meeting with HMRC on 11 March attended by CIOT and ATT representatives on the implementation of the new version of the TRS, HMRC have announced that:

“As you are aware the Trust Registration Service will be extended to enable non-tax paying trusts to register in compliance with the Money Laundering Regulations. We are now able to provide more detail on the timescales and registration deadlines:

  • We now expect the IT system to open for registrations in summer 2021 rather than the spring.
  • We appreciate this will be a cause for concern in terms of the current registration deadline of March 2022.
  • We therefore intend to extend that deadline within the legislation in order to provide trustees and agents of existing trusts with approximately 12 months in which to register from the date of IT delivery.
  • We will provide further updates and clarification on this in due course.”
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