The 1st September deadline for registering with the Trust Registration Service is less than a month away. Register online now to avoid a potential £5000 penalty in the future.

Since October 2020, HMRC has required all trusts to register with the Trust Registration Service, regardless of whether or not they are liable to pay UK tax. The deadline for registering with the online service is 1st September 2022. 

What is the Trust Registration Service?

The Trust Registration Service provides trustees and personal representatives of complex estates with a single online route to comply with registration obligations laid out by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. 

Previously, trustees only had to register with the Trust Registration Service if they had a UK tax liability. You may find that you have financial arrangements that have not been reported to HMRC before as they do not attract a tax liability – for example:

  • Investment bonds within a trust wrapper 
  • Bare trusts where you hold assets on behalf of someone else 
  • Discounted gift trusts set up for Inheritance Tax Planning

Under the new rules, it is a legal requirement to disclose these arrangements going forward.  

The most effective way to ensure that you have declared everything you need to declare to the Trust Registration Service is to speak to a tax specialist about your personal circumstances. 

What information do I need to submit to the Trust Registration Service?

Both tax-paying and non-tax paying trusts have to report their beneficial ownership with the Trust Registration Service. The information you will be required to submit includes: 

  • The Settlor 
  • The Trustees
  • Named beneficiaries
  • Individuals who have control or powers over a trust 
  • Potential beneficiaries named in a letter of wishes

Reporting your beneficial ownership is not necessarily a one-off exercise. If your trust remains non-tax paying, there is no requirement to update the register annually. However, any changes that occur, such as a change of Trustee, must be entered on the register within 90 days. 

What actions do I need to take?

You need to speak to your financial and legal advisors immediately to ensure you are registered and compliant with the Trust Registration Service before the final deadline on 1st September 2022. 

Are there any exemptions?

You can find out more about exemption criteria in the Trust Registration Service Manual on the HMRC website. 

What happens if I miss the registration deadline?

Initially, you will receive a reminder letter from HMRC. Trustees that are found to have deliberately ignored their registration obligations could face a £5000 penalty per offence. 

Our specialist private client team has been supporting clients with registration and compliance for the Trust Registration Service since the new rules were introduced. If you would like one of our tax experts to handle the registration process for you, contact us today to discuss your needs.