The Association of International Life Offices (AILO) is calling for greater clarity on Irish trust registration.
In a statement today (28 February), AILO warns that UK advisers to UK and non-EU trusts taking out life policies with Irish providers can expect the imminent reintroduction of the Irish trust registration requirements.
Since the introduction of the Central Register of Beneficial Ownership of Trusts or CRBOT in 2022, UK and non-EU trusts with a ‘business relationship’ in Ireland have been unable to register under CRBOT.
On behalf of the life sector, AILO and other trade bodies have raised a number of issues with the Irish Revenue seeking clarification on their plans and timelines for the implementation of a technical solution to this registration issue.
The clarity sought has focused on the:
• Simplification of the registration process for trustees;
• Registration of existing life company ‘back book’ policies written under trust;
• Practicalities of ongoing CRBOT checks on UK and non-EU trusts;
• Difficulties life companies will face in implementing changes to product literature or website content in the absence of Irish Revenue implementation timelines; and
• Potential impact of the new EU AML package, which will come into effect in July 2027 on CRBOT registration requirements.
A Pilot registration process began in October 2024, but this is due to end shortly, with the new registration system likely to be fully implemented for non-EU trustees in the near future. As part of this, the Irish Revenue is expected to deliver a number of enhancements to the system used during the Pilot.
It has also advised that these enhancements will be supported by an updated Quick Reference Guide and FAQ’s. They have also committed to providing an industry stakeholder presentation following launch.
However, clarity on the key issues identified has yet to be received, and it currently seems likely that CRBOT will be introduced for UK and non-EU trusts with these issues unresolved.
UK advisers and trustees should continue to monitor the situation closely, the AILO statement concluded.
The Registrar can be contacted by e-mail at TrustRegister@revenue.ie.
