The recent publication of the European Union (Modifications of Statutory Instrument No. 110 of 2019) (Registration of Beneficial Ownership of Certain Financial Vehicles) Regulations 2020 (the "2020 Regulations") provides welcome clarity regarding the beneficial ownership filing requirements that will apply to unit trusts, ICAVs and credit unions. The 2020 Regulations provide for the establishment of the Register of Beneficial Ownership of Irish Collective Asset-management Vehicles, Credit Unions and Unit Trusts (the "Register") which is expected to be operated by the Central Bank of Ireland. In-scope entities will have 6 months to file their first returns to the Register. Helpfully, the definition of "beneficial owner" in relation to unit trusts has been amended including to clarify that there will be a "greater than 25 per cent" threshold when determining whether a unitholder is deemed to be a beneficial owner of a unit trust.
Originally published July 1, 2020.
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