Employee Benefit Trusts (EBTs) with relevant U.K. tax liabilities have been required to register with the U.K. tax authorities’ Trust Registration Service (TRS) since June 2017.
Changes introduced by the Fifth Money Laundering Directive mean that, subject to limited exceptions, employee trusts without a relevant U.K. tax liability may also be required to register with HM Revenue & Customs (HMRC) by 1 September 2022.
Note that whilst EBTs often operate in connection with employee share plans, the obligation to register and report certain information under the TRS is separate from an employer’s annual U.K. employee share plan reporting (see our report published today in GMS Flash Alert 2022-084, 15 April 2022).