HMRC has requested that Trustee Company Service Providers (TCSPs) who failed to register with HMRC by the 30 September deadline should still submit application forms and fees.
Broadly TCSPs may have to register with HMRC under the Money Laundering Regulations 2007. According to the MLR 9 guidance sole practitioners and firms are not deemed to be TCSPs (and are not required to register with HMRC) if they provide trustee services limited to occupational pension schemes (See EPB bulletin from 5 August 2008).
HMRC has said that to avoid penalties or prosecutions TCSPs who have missed the deadline should send HMRC completed application forms and appropriate fees without further delay. gislative changes might be made.