Regulations on money laundering and terrorist financing came into force at the end of June 2017 which, among other things, require schemes which have incurred certain tax liabilities in the 2016/17 tax year to provide information to HM Revenue & Customs (“HMRC”). (For more information on the new requirements imposed by the regulations, please see our recent legal update.) HMRC has now announced an extension to the deadline for providing this information.

The obligation to provide information to HMRC applies where the scheme has incurred a liability in the 2016/17 tax year to pay income tax, capital gains tax, inheritance tax, stamp duty land tax, stamp duty reserve tax or land and buildings transaction tax on the scheme’s assets or income. Trustees must register with HMRC’s Trust Registration Service (“TRS”) to provide the required information. Following HMRC’s announcement, the deadlines for TRS registration and provision of the required information are as follows:

  • Schemes which are not already registered with HMRC for self-assessment and have incurred an income tax or capital gains tax liability in the 2016/17 tax year must register with the TRS by 5 January 2018, and must provide the required information via the TRS by 31 January 2018.
  • In all other circumstances, schemes must register with the TRS and provide the required information by 5 March 2018 (previously the deadline was 31 January 2018).

If a scheme has not incurred one of the applicable tax liabilities in the 2016/17 tax year, it is not required to register with the TRS or to provide information to HMRC.