Q&As

A trust owns two US Limited Liability Companies (LLCs). The LLCs jointly own a Scottish limited partnership (SLP) which holds UK situs assets. The SLP is going to register under The Scottish Partnerships (Register of People with Significant Control) Regulations 2017. If no UK-source income is paid to the trust, do the trustees need to register the trust with HMRC under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017?

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Published on LexisPSL on 15/08/2017

The following Private Client Q&A provides comprehensive and up to date legal information covering:

  • A trust owns two US Limited Liability Companies (LLCs). The LLCs jointly own a Scottish limited partnership (SLP) which holds UK situs assets. The SLP is going to register under The Scottish Partnerships (Register of People with Significant Control) Regulations 2017. If no UK-source income is paid to the trust, do the trustees need to register the trust with HMRC under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017?

In this Q&A we have assumed the following:

  1. the partnership in question is a Scottish limited partnership

  2. HMRC accepts that the US Limited Liability Companies (LLCs) which own the Scottish limited partnership (SLP) are opaque for UK tax purposes

  3. the SLP is going to register under The Scottish Partnerships (Register of People with Significant Control) Regulations 2017, SI 2017/694

  4. the trust in question is not UK resident for UK tax purposes

The key issue is whether, in any particular tax year, the trust is a ‘taxable relevant trust’. A taxable relevant trust

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