Statement from AILO (the Association of International Life Offices)

As a result of recent communication between an AILO Member and the Irish Revenue Commissioners, AILO understands that UK express trusts holding an investment bond issued from Ireland are required to register on the Irish trust register.  This is because, under the Irish Revenue’s current guidance and interpretation of the 5MLD,  UK express trusts which hold an Irish investment bond will be deemed to have a ‘business relationship’ in Ireland.  The need to register still applies even if the trustees have registered on the UK register as a UK express trust, owing to the requirements deriving from an EU Directive. However, we also understand that the process of registering on the Irish register presents practical and technical difficulties for UK trustees.

In addition to raising the wide ‘business relationship’ rules with appropriate bodies in Ireland in order to seek a pragmatic solution which does not impose unnecessary dual registration requirements for Trustees, AILO also intends to highlight to the Irish Revenue the practical difficulties of registration for UK trustees. Advisers and their trustees struggling to register should, however, make this known to the Irish Revenue Commissioners through the available channels.

We will keep you informed of our progress.