What information is required for CRBOT

Trustees must submit information in relation to each beneficial owner of the trust.

A beneficial owner is a natural person and the details of individual beneficial owners of a trust are required on the Central Register of Benefical Ownership of Trusts (CRBOT).

A beneficial owner is any one of the following:

  • any individual who is entitled to a vested interest in the trust
  • a class of beneficiaries, such as a trust set up for the benefit of a group of beneficiaries
  • any individual who has control over the trust
  • the settlor
  • the trustee
  • the protector.

Note

If you are in any doubt as to whether you are a beneficial owner of a trust you should seek professional advice.

Information to be filed in relation to beneficial owners

The information to be filed in relation to each Beneficial Owner includes:

  • name
  • address
  • date of birth
  • Personal Public Service Number (PPSN)
  • nationality
  • country of residence
  • statement of the nature and extent of the interest held, or the control exercised
  • date entered into the CRBOT as the beneficial owner
  • cessation date as a beneficial owner.

If the individual does not have a PPSN they must provide and upload proof of one of the following:

  • foreign tax registration number
  • passport number
  • and
  • national identity number.

Beneficial ownership of legal entities

The natural person or persons who ultimately own or control a legal entity are the beneficial owners. A legal entity cannot be a beneficial owner. 

The beneficial ownership information of the legal entity may have been provided on another Central Register. If it has, the trustee can cross reference to the other register.

Please refer to the RBO website for further information on the identification of beneficial owners of legal entities.

Where the beneficial ownership details of a legal entity are not on another central register 

The following details are required:

  • name of legal entity
  • registered address of the legal entity
  • statement of the nature and extent of the interest held, or control exercised, in relation to the relevant trust.

Once the legal entity has entered its relationship to the trust, the beneficial owner type of 'other natural person exercising effective control' can be selected on the CRBOT. This will allow you to provide the details of the individual beneficial owners of that legal entity.

Note

You must provide the individual beneficial ownership details of a legal entity where the legal entity is a:

    • beneficiary
    • trustee
    • settlor
    • protector
    • or
    • has control over the trust.

Where the beneficial ownership details of a legal entity are on another central register

The following details are required:

  • name of legal entity
  • registered address of the legal entity
  • statement of the nature and extent of the interest held, or control exercised, in relation to the relevant trust
  • filing number on the other Central Register
  • and
  • name of the register on which they are already registered.

Note

The CRO number is the appropriate filing number for legal entities registered on the Central Register of Beneficial Ownership of Companies and Industrial and Provident Societies (RBO).

For legal entities registered on the Central Register of Beneficial Ownership of Irish Collective Asset-management Vehicles, Credit Unions and Unit Trusts it is not necessary to provide a reference on CRBOT. However, the name of this register is still required.

What is meant by the nature and extent of the interest held?

The nature of a person’s interest is their role in the trust, for example as a trustee.

The extent of the interest held is demonstrated by indicating if they are:

  • the sole beneficiary
  • one of several beneficiaries
  • or
  • one of hundreds and entitled to an equal share of the trust’s assets or to a specific percentage.

What is meant by the nature and extent of control exercised?

Control exercised includes:

  • holding a power to add or remove a person as a beneficiary
  • power to appoint or remove trustees
  • power to dispose of or invest the trust property.