We have been successful in registering a handful of UK trusts on the Irish Trust Register (CRBOT). Some are already on the UK Trust Register but need to be added to the Irish Register due to the nature of the assets held (Irish Bonds).
However, we have noticed yesterday that a new message appears when adding a Trustee that is an Entity and is not already registered on a central EU Registration site (so HMRC’s Trust Register does not count!).
We have also received a message regarding one of our Trusts that was registered on the system back in 2022 stating
Please be aware that once the legal entity (Trust Company), has entered its relationship to the trust (in your case Trustee) then they should also add the beneficial owner type of ‘other natural person exercising effective control’ on the CRBOT to provide the details of the individual beneficial owners of that legal entity. Can you please update CRBOT with the information in relation to the ‘other natural person exercising effective control’ details or any information that is required under the above Regulations for this trust.
The legislation is not particularly clear as to who would need to be added as an 'other natural person exercising effective control’, especially if the Trustee is a legal Entity with multiple employees.
Has anyone else come across this issue yet? Our current thinking is that we would have to add in the Trustee Company Directors.