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Trust registration in Ireland
Trustees of UK trusts that hold investments, insurance policies and/ or property based in Ireland, or have a business relationship in Ireland, are now required to register their trust on Ireland’s Central Register of the Beneficial Ownership of Trusts (CRBOT).
Common examples of where the trustees have a business relationship in Ireland would be where the trustees are holding an ‘offshore’ investment bond or insurance policy issued by a company based in Ireland or have established (or are establishing) a business relationship with a financial institution.or other professionals, such as solicitors, accountants or estate agents.
CRBOT
More information on CRBOT is available on the Irish Revenue Commissioners’ (IRC) website at https://www.revenue.ie/en/crbot/index.aspx.
Whilst the deadline for the registration of trusts in existence on, or before, 23 April 2021 was 23 October 2023, and for newer trusts, within 6 months of their date of creation, it was extremely complicated for non-Irish resident trustees to register their trust on CRBOT. The IRC, therefore, provided a waiver from penalties for late registration of non-Irish resident trusts whilst they developed an easier route for registration.
The new system became available on 4 March 2025 so trustees of non-Irish resident trusts that hold investments, insurance policies and/ or property in Ireland or have an Irish business relationship should consider registering their trust on CRBOT as soon as possible to avoid the imposition of penalties.
It should also be noted that some trusts that may be treated as excluded trusts in the UK under HMRC’s Trust Registration Service (TRS) may still require registration on CRBOT as different criteria apply under Irish legislation. The IRC’s website gives details of excluded arrangements from registration on CRBOT.
The information required to register a trust on CRBOT is different to that required to register the trust on the TRS. One major difference is the requirement to provide physical proof of identity for each named party involved in the trust (generally a copy of a valid passport or proof of a tax identification number (TIN) such as a National Insurance number for UK residents). This proof of identity must be updated if the details change, such as on renewal of a passport.
Trusts already registered in another Member State
Trustees of a trust within the scope of CRBOT where the trust has already been registered in another Member State must acquire a certificate from the Registrar in that Member State and supply this certificate to CRBOT. This is relevant where:
- the trust is administered in more than one Member State; or
- two or more trustees reside in different Member States; and
- the trust has been registered on the Central Register in another Member State; and
- the information held on that Central Register is the same as that required to be registered on CRBOT (apart from individual’s Irish Personal Public Service Numbers (PPSNs).
Once a trust has been registered on CRBOT
Once a trust has been registered on CRBOT, the trustees will need to provide evidence of the registration to obliged entities (also known as designated persons) in Ireland, such as the provider of an offshore investment bond or insurance policy, other financial institutions and/ or those providing professional services, such as solicitors, estate agaents and accountants. This evidence includes the registration number of the trust on CRBOT and various pages from the documents submitted when the trust was registered on CRBOT.
What happens if a trust requiring registration is not registered on CRBOT?
The IRC suspended penalties for non-registration of non-Irish resident trusts whilst the new systems were being developed. Now that these have gone live, penalties for non-registration of non-Irish trusts may be reintroduced at any time.
Obliged entities (designated persons) are required to check that a trust has been registered and, where this is not the case, and the trust is not excluded from registration, they are required to not process certain transactions which could significantly increase the administration requirements of trustees and mean that, say, withdrawals or surrenders cannot be taken from an offshore investment bond or a property held in the trust cannot be sold. The obliged entity (designated person) is also required to check the information registered on CRBOT (they have restricted access to CRBOT) against their records and, where there is a discrepancy, report this to the CRBOT Registrar.
Trusts already registered on HMRC’s Trust Registration Service (TRS)
Registration on CRBOT is required even if the trustees have already registered the trust on HMRC’s Trust Registration Service as, post-Brexit, EU tax authorities do not recognise the TRS registration due to the UK no longer being part of the EU.
The TRS and trusts already registered on another EEA Member State’s register
Where trust that is established in a Member State of the European Economic Area (EEA) has already been registered on the beneficial ownership register of that Member State, that registration takes priority over the need to register the trust on the TRS.
Trustees of UK trusts should, however, first determine whether the trust is required to register on the TRS. HMRC’s Trust Registration Service Manual provides full information on the TRS.
Can Trustee Support Services help me to register a trust on CRBOT?
Yes, please contact us if you are an adviser to, or trustee of, a trust requiring registration on CRBOT. We are currently developing systems to make registration easier but are happy to register trusts in the meantime.
