The PPF have indicated in relation to one of our clients with a French guarantor that they are prepared (on a case by case basis) to consider accepting documents submitted after the 31 March deadline in appropriate circumstances. (See our website update for a detailed explanation of the issue, relevant to schemes with contingent assets where the provider is domiciled in the EU).
Our client has been asked to give an indication of when they expect to receive the appropriate French legal opinion.
This is very helpful of the PPF and we urge all Trustees who might be facing difficulty with the 31 March deadline to speak to the PPF where they have an EU domiciled provider of a contingent asset, and the cost/benefit analysis suggests that it is worthwhile pursuing the levy reduction this year. The PPF cannot formally pre-approve an extension, but will be able to explain the basis on which it will consider whether late submissions will be accepted. The PPF can be contacted by emailing email@example.com or calling 0345 6002541 (option 3).
Regardless of PPF levy considerations, Trustees with EU domiciled guarantors should consider the implications of Brexit.
If you are re-certifying a contingent asset where the provider is EU domiciled, the PPF may require a new legal opinion from your EU lawyer