Legal Guidance and Research / Experts / Gemma Davies
Gemma Davies#6843
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Gemma Davies

BDO
Gemma is part of the Family Private Wealth team in BDO’s London Private Client Services team.

She has over 18 years experience in the area of Trusts, Estates and Family Charities, both offshore and onshore, and is one of the firm’s champions of all aspects relating to the taxation, accounting and compliance matters of UK Trusts.

Gemma works closely with other professionals, especially solicitors and corporate trustees, working with them on a wide range of projects and planning strategies for clients and their families.

Practice Area

Panel

  • Contributing Author

Membership

  • CIOT
  • STEP

Education

  • University of Exeter (2001)

1 Contributions by Gemma Davies

HMRC Trust Registration Service (TRS): UK summary table of registration duties, exemptions, deadlines, update obligations and beneficial ownership information under the Money Laundering Regulations 2017–2022
PRACTICE NOTES
HMRC Trust Registration Service (TRS): UK summary table of registration duties, exemptions, deadlines, update obligations and beneficial ownership information under the Money Laundering Regulations 2017–2022
This Practice Note sets out when there is an obligation to register a trust with the Trust Registration Service (TRS). The material presented in this table is drawn from the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as subsequently amended by the Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020 (MLR 2020), SI 2020/991, together with the Money Laundering and Terrorist Financing (Amendment) Regulations 2022 (MLR 2022), SI 2022/137. On 15 March 2021, HMRC indicated that the original deadline of 10 March 2022 for registering trusts on the TRS, where registration is mandated under the EU’s Fifth Anti-Money Laundering Directive (EU) 2018/843 (5MLD) and MLR 2020, SI 2020/991, would be deferred by around twelve months from the point at which the expanded TRS was released. The expanded TRS became accessible to all users on 1 September 2021. It was also made explicitly clear that any non-taxable trusts in existence on or after 6 October 2020 must complete their registration by 1 September 2022, that trustees have 90 days to update the TRS where any changes occur for both taxable and non-taxable trusts, and that trusts needing to...
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