Non-Reporting Financial Institutions: Trustee Documented Trust
NRFI: Trustee Documented Trust
Trustee-documented trusts are Non-Reporting Financial Institutions (NRFI) for all the regimes.
A trustee-documented trust is a trust that is a financial institution [see IEIM400600] where the trustee of the trust is itself a Reporting Financial Institution [see IEIM402100] and reports all the information required in respect of the Reportable Accounts [see IEIM401520] of the trust. In such a case, the trust itself becomes a Non-Reporting Financial Institution and the trustee Financial Institution must report the information that the trust would otherwise have reported. Therefore, when registering a trustee-documented trust on the HMRC portal, the trustee is the reporting financial institution, not the trust.
For FATCA reporting, the GIIN used will be that of the trustee, acting in its capacity as trustee.
The trustee must identify, when reporting, the trustee-documented trust in respect of which it fulfils the reporting and due diligence obligations. This should be done by including the trust name in the account number or account identifier section when completing the return for the trust on the HMRC portal. For an xml report the trust name should be included in the account number or account identifier field of the schema.