TRS – do you still need to register your trust?

Year Published: 2022

If you still need to register your trust under the Trust Registration Service (TRS), the deadline has been extended. Helen Kelly explains.

Earlier in the year, we discussed the Trust Registration Service (TRS) and the additional regulations that came into force on 6th October 2020 as a result of the Fifth Money Laundering Directive (5MLD). Recently, HMRC has announced that a deadline extension for the TRS will be implemented.

It will be a requirement to register all UK express trusts (regardless of their tax liabilities) unless they fall under the list of exemptions – some of these include trusts created by law, for example those occurring in certain circumstances if an individual dies without a will, pension trusts, charitable trusts, trusts for vulnerable beneficiaries or bereaved minors, personal injury trusts and co-ownership trusts, amongst others. Existing pilot trusts that hold assets with a value of less than £100 are also exempt unless further assets are added.

Taxable Trusts

HMRC set a deadline for all existing ‘taxable’ trusts to register on the TRS and that deadline has since passed.  It is therefore important to register now if you, as a trustee, have not done so already.


For trusts not registered for Self Assessment, the deadline for registering will depend on the circumstances involved:

  • Where the trustees incur an Income Tax or a Capital Gains Tax liability for the first time in a given tax year, then the registration deadline is 5 October after the end of that tax year
  • Where the trustees incur either an Inheritance Tax, Stamp Duty Land Tax, Stamp Duty Reserve Tax, a Land and Buildings Transaction Tax (Scotland) or a Land Transaction Tax (Wales) liability in that tax year, then the registration deadline is 31 January after the end of that tax year


For those trusts that complete annual tax returns, the trustee, or their agent, will need to keep the Trust Register up to date (with changes of trustees, addresses, beneficiaries etc.) and confirm online to HMRC that this has been done, or confirm that no changes have arisen during the tax year.


Non-Taxable Trusts

The Fifth Money Laundering Directive (5MLD) has since been implemented and new rules introduced from 6 October 2020 extend the scope of the trust register to all UK and some non-UK trusts that are currently open, i.e., removes the need for the trust to be ‘taxable’.  As a result, this brings many non-taxable express trusts into the scope of needing to register on the TRS.


The deadline for registering these trusts via the TRS is 1 September 2022.

For further information regarding the Trust Registration Service or for any other Trust related matter, please contact Helen Kelly on 0161 475 7689 or email [email protected].

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