Do I need to register my trust’s offshore bond in Dublin?

If you have an offshore investment bond issued from Dublin and it’s held in a UK trust, there’s a new rule you need to be aware of.

From 5 March 2025, UK trusts holding these Irish bonds must be registered not just with HMRC in the UK, but also on Ireland’s own Central Register of Beneficial Ownership of Trusts (CRBOT). This is part of Ireland’s anti–money laundering rules.

Why this matters

• It’s the law: all UK trusts with Irish-issued bonds must be on the Irish register, even if they’ve been set up for years.

• Your provider will check: Irish bond providers are now required to confirm you’re registered before allowing withdrawals, trustee changes, or policy assignments. If you’re not registered, your bond could effectively be frozen until you are.

• Penalties are real: if you ignore the rule, Irish authorities can impose fines and, in extreme cases, prosecute.

Who’s affected?

Any UK express trust (discretionary trusts, bare trusts, loan trusts, discounted gift trusts, flexible reversionary trusts, etc.) that holds an Irish offshore bond, whether bought years ago or this year.

Deadlines

• New trusts (established on or after 5 March 2025): Register within six months of establishing the trust or purchasing the bond.

• Existing trusts: Register as soon as possible, as the grace period has expired.

What’s involved

Registering is straightforward but requires detail. The trustees (or someone they authorise) need to:

1. Go to the Irish Revenue’s CRBOT portal for non-resident trusts.

2. Provide trust details (name, date created, type).

3. List everyone involved, including the settlor, trustees, named beneficiaries, and anyone with control.

4. Upload a photo ID and proof of address for each person listed.

5. Submit the form and keep your CRBOT registration number safe.

Your adviser can help you with this.

What you should do now

1. Check if your trust holds an Irish bond – common providers include Canada Life International, Prudential International, Aviva International, Zurich, Utmost, and others based in Dublin.

2. Ensure your trust is registered with HMRC – UK registration is still required.

3. Gather your paperwork – trust deed, ID and address proof for everyone named.

4. Get the Irish registration done – before you need to access the bond.

This change doesn’t affect the tax treatment of your bond. It’s about transparency, not paying more tax. However, it does mean that without registration, you may not be able to withdraw money or make changes when you need to.

If you need advice, we’re here to help. Schedule a free, no-obligation chat here. A guide on selecting a financial advisor is also available here.