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The key to understanding the reporting deadlines is to remember whether the trust is due to report under 4MLD or 5MLD and this is primarily a differential between taxable or non-taxable trusts. A trust needs to report under 4MLD if it is taxable but more specifically where trustees pay that tax.

Trusts reportable under 4MLD – should have reported to the TRS by 5th March 2018 with new trusts having just 30 days from completion to register.

Regardless there is no mention of penalties in the HMRC TRS manual.

Systems due to register trusts, reportable under 5MLD, are to be live from early September 2021. The deadline will be 12 months from that date for existing trusts & thereafter new trusts will have 30 days from completion to register.

The position on penalties for late reporting under 5MLD will be clarified in the next TRS manual.

Regardless of whether we end up with penalties for late reporting there is a very real concern that where trusts are late in reporting this is an AML fail. Amongst the very real repercussions is the fear that providers/DFM’s/Platforms will stop taking instructions & indeed advice fees may be blocked.

Click below for more information on deadline dates & penalties for late or non-reporting to the TRS.

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