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Is a Tax Declaration needed where the entity applicant is not a trust?

Yes, a Tax Declaration must be completed for all new applications. The information provided to us will allow us to assess whether the accountholder or controlling persons are reportable or not.

In a number of limited circumstances we may rely on publicly available information which would allow us to determine if the Financial Institution is compliant with the Regulations or where information is provided to us that confirms that the applicant is a UK registered Pension Scheme, by sending us the Registered Pension Scheme number, in these circumstances a Tax Declaration isn’t needed.

Further examples

Non-UK registered pension schemes - if your client is a non-UK registered pension scheme and they are based in Jersey, Guernsey or the Isle of Man and they and they are a Compliant Financial Institution with a Global Intermediary Identification Number (GIIN), which is issued to Financial Institutions which are complying with the Regulations. We will allow for the GIIN to be provided to us as proof of their compliant status under the Regulations. There will be no need for the Scheme Trustees to complete the Tax Declaration.

UK registered pension schemes - most UK registered pension schemes are classed as an ‘Exempt Beneficial Owner’ and not reportable by Quilter. However, to ensure our compliance with the Regulations we must be satisfied that the Scheme is a UK registered pension scheme. Instead of completing the Tax Declaration, we may allow for the Trustees to confirm in writing to us that they are a UK registered pension scheme and ask them to confirm the Registered Pension Scheme number (PSTR) when an application is submitted.