The European Union (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021 (the ‘Regulations’) requires trustees of express trusts to file beneficial ownership information in a newly created Central Register of Beneficial Ownership of Trusts (the ‘CRBOT’).
The purpose of the Regulations is to improve transparency in Ireland and the EU by making clear who is the beneficial owner and ultimately owns and controls assets in Irish trusts.
Trusts Required to Register and Excluded Arrangements
All ‘Relevant Trusts’ being any trust whose trustees are resident in Ireland, or which are otherwise administered in Ireland, are obliged to submit information to the Register.
For the purposes of the Regulations, a ‘Relevant Trust’ is an express trust established by deed or other declaration in writing, save for ‘excluded arrangements’.
‘Excluded Arrangements’ are as follows:
The Regulations also apply to trusts where, although the trustees are not a resident of the EU and the trust is not otherwise administered in the EU, the trustee enters into a business relationship in Ireland or acquires land or other real property in Ireland in the name of the trust.
For the purpose of the Regulations, a ‘Beneficial Owner’ of a ‘Relevant Trust’ includes the following:
Information to be submitted on the CRBOT
The following information is required to be submitted to the Register where the beneficial owner is an individual:
The following information is required to be submitted to the Register where the beneficial owner is a legal entity registered on another Central Register in Ireland or the EU:
The Revenue Commissioners established a ‘Trust Register Portal’ on Revenue Online Service (ROS) to facilitate filings.
For trusts that were established on or before 23 April 2021, the registration deadline is 23 October 2021. Trusts created after 23 April 2021 must be filed within 6 months of their creation.
Inspection of the Trust Register
Unrestricted access to inspect the Trust Register will be available to the following:
Restricted access to inspect the Trust Register will be available to the following:
For further information in relation to this matter, please contact Bríd McCoy (Partner), or your usual AMOSS contact.
 If the individual does hold have a PPSN they must provide a Foreign Tax Registration Number, a Passport Number or a National Identity Number issued by the authority in the State concerned.