Jurisdiction(s):
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AEOI registration under 2025 ITC Amendments: specified non‑reporting trusts—trust corporations, trustee‑documented, and lay‑trustee private company shares

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Amendments to the International Tax Compliance Regulations 2015 (2015 regs), SI 2015/878, introduced by the International Tax Compliance (Amendment) Regulations 2025, SI 2025/740, have brought in a compulsory Automatic Exchange of Information (AEOI) registration obligation for certain trusts treated as ‘specified non-reporting financial institutions’. Under the 2015 regs, SI 2015/878, reg 24(1), a specified non-reporting financial institution is ‘a non-reporting financial institution which is a trust within the meaning of Section VIII(B)(1)(e) of the CRS or paragraph II(D) of Annex II to the FATCA agreement’. Set out below is a concise overview of the components of that definition.

Financial institution (IEIM400610)

The FATCA and CRS frameworks recognise four common categories of Financial Institution:

custodial institution
depository institution
investment entity
specified insurance company

Where a private trust satisfies any Financial Institution definition, it will most commonly be treated as an Investment Entity...

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Web page updated on 27/05/2026

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