HMRC Trust Registration Service (TRS)

My downloadable guide provides practical instructions for Lead Trustees on registering trusts under HMRC’s Trust Registration Service (TRS). It is designed for common trust types used in financial planning and highlights key compliance requirements following the 5th EU Anti-Money Laundering Directive.

Purpose and Scope

  • All UK “Express Trusts” (written trusts) must register via TRS since 6 October 2020.
  • Registration applies even if the trust is non-taxable, with limited exemptions (e.g., certain life policy trusts, pilot trusts under £100, co-ownership trusts, bereaved minors’ trusts and Personal Injury Trusts).
  • Failure to register can result in penalties up to £5,000 per trustee.

Key Deadlines

  • New trusts: Register within 90 days of creation.
  • Existing trusts: Those created before 6 October 2020 should have registered by 1 September 2022.

Tax Considerations

  • Trusts may be taxable depending on type and assets:
    • Bare Trusts: Income/gains taxed on beneficiary.
    • Interest in Possession Trusts: Taxable if income is accumulated.
    • Discretionary Trusts: Taxable on trustees if settlor deceased.
  • Relevant taxes include Income Tax, Capital Gains Tax, Inheritance Tax, Stamp Duty Land Tax, and Stamp Duty Reserve Tax.

Information Required for TRS

  • Trust details: Name, creation date, property details, Trust Deed.
  • Individuals: Settlor(s), trustee()s, beneficiaries, protectors—full personal details including NI numbers for settlor(s) and lead trustee.
  • Corporate entities: UTR, address, contact details.

Registration Process

  • Create a Government Gateway account (separate for each trust).
  • Complete TRS online form, including tax status and all required details.
  • Obtain and maintain a Certificate of Registration, dated within 30 days for financial institutions.

Additional Considerations

  • EU Registration Trusts with Irish-issued life assurance bonds must also register in Ireland.
  • Automatic Exchange of Information (AEIO) Trust using a Discretionary Fund Manager are now (from 2025) required to additional register under this legislation.
  • Legal Entity Identifier (LEI) required for trusts using discretionary fund managers with direct equities or ETFs.

Support Offered

I help with TRS registration, Irish trust registration, AEIO, and related trust planning services.

Download theHMRC TRS Registration Guide