FIC Accountable Institution Test – PCC 6A

Determine whether your accounting practice carries on business as a Trust and Company Service Provider under Schedule 1 Item 2.

Scenario validation

Each scenario is a complete set of prefilled factual answers run through the same rule engine used for live assessments. Load one to inspect the questionnaire and the resulting determination report.

Annual financial statements and tax returns only

NOT INDICATED AS AN ITEM 2 TCSP ON THE ANSWERS PROVIDED

The practice prepares annual financial statements and tax returns. It performs no formation, secretarial, nominee or trust-property work.

Expected: Should not automatically trigger Item 2. The outcome depends on there being no additional TCSP activities.

  • A. Company-service gatewayNot triggered on current facts
  • B. Nominee gatewayNot triggered on current facts
  • C. Trust-creation gatewayNot triggered on current facts
  • D. Trust-property gatewayNot triggered on current facts

Company formation and statutory changes as a recurring service

ACCOUNTABLE INSTITUTION – ITEM 2 TCSP

The practice forms companies for clients and regularly changes directors and shareholdings, files CIPC returns and prepares resolutions.

Expected: Company-service gateway (A) likely triggered.

  • A. Company-service gatewayTriggered
  • B. Nominee gatewayNot triggered on current facts
  • C. Trust-creation gatewayNot triggered on current facts
  • D. Trust-property gatewayNot triggered on current facts

Referral only to an independent registration service

NOT INDICATED AS AN ITEM 2 TCSP ON THE ANSWERS PROVIDED

A client asks about forming a company. The practice refers them to an independent registration agent and takes no further step.

Expected: Ordinarily no trigger on that fact alone; boundary questions test whether any preparation or coordination occurred.

  • A. Company-service gatewayNot triggered on current facts
  • B. Nominee gatewayNot triggered on current facts
  • C. Trust-creation gatewayNot triggered on current facts
  • D. Trust-property gatewayNot triggered on current facts

Partner acts as nominee shareholder

ACCOUNTABLE INSTITUTION – ITEM 2 TCSP

A partner holds shares in client companies in her own name for the benefit of the beneficial owners, on their instructions.

Expected: Nominee gateway (B) triggered.

  • A. Company-service gatewayNot triggered on current facts
  • B. Nominee gatewayTriggered
  • C. Trust-creation gatewayNot triggered on current facts
  • D. Trust-property gatewayNot triggered on current facts

Trust structures created for clients

ACCOUNTABLE INSTITUTION – ITEM 2 TCSP

The practice drafts trust deeds, arranges founders and trustees and supports registration as part of its estate planning offering.

Expected: Trust-creation gateway (C) triggered.

  • A. Company-service gatewayNot triggered on current facts
  • B. Nominee gatewayNot triggered on current facts
  • C. Trust-creation gatewayTriggered
  • D. Trust-property gatewayNot triggered on current facts

Acting as trustee and controlling trust assets

ACCOUNTABLE INSTITUTION – ITEM 2 TCSP

Directors of the practice act as trustees, sign on trust bank accounts, approve investments and administer trust property.

Expected: Trust-property gateway (D) triggered.

  • A. Company-service gatewayNot triggered on current facts
  • B. Nominee gatewayNot triggered on current facts
  • C. Trust-creation gatewayNot triggered on current facts
  • D. Trust-property gatewayTriggered

Trust financial statements and tax returns only

NOT INDICATED AS AN ITEM 2 TCSP ON THE ANSWERS PROVIDED

The practice prepares trust financial statements and tax returns from information supplied by the trustees, and executes nothing.

Expected: Should not automatically trigger the trust-property gateway.

  • A. Company-service gatewayNot triggered on current facts
  • B. Nominee gatewayNot triggered on current facts
  • C. Trust-creation gatewayNot triggered on current facts
  • D. Trust-property gatewayNot triggered on current facts

Company secretarial work bundled into an accounting fee

ACCOUNTABLE INSTITUTION – ITEM 2 TCSP

The practice performs company secretarial work, CIPC filings and resolutions, but never invoices separately for it.

Expected: Fee bundling must not prevent a trigger where substantive Item 2 services are carried on.

  • A. Company-service gatewayTriggered
  • B. Nominee gatewayNot triggered on current facts
  • C. Trust-creation gatewayNot triggered on current facts
  • D. Trust-property gatewayNot triggered on current facts