Trust Registration Service (TRS) – Action now required

Jonathan Matchett
Financial Planning
Jonathon Matchett, Lovewell Blake Financial Planning

Following the implementation of the EU Fifth Anti-Money Laundering Directive (5AMLD), there is a requirement for certain trusts to be registered on a central government list. This is called the Trust Registration Service (TRS), and when it was initially introduced in 2018, many non-tax paying trusts were exempt from registering.

Jonathon Matchett, Lovewell Blake Financial Planning

Since then, the scope of the TRS has expanded to include almost all trusts. 

After a period of grace, whilst they were getting their systems up and running, HMRC announced recently that the Trust Registration Service has now opened. This means that trusts which are newly required to register, can now do so. Indeed, they must register by a certain date.

This list is to be administered via an online portal, managed by HMRC.

HMRC have given guidance as to which trusts are exempt, under particular circumstances, and this currently includes the following: 

  • Trusts holding insurance policies while the life assured is still alive – if it only pays out in certain scenarios.
  • Trusts holding proceeds from insurance policies received on death of the life assured – in certain circumstances, and with a time limit.
  • Pilot trusts – trusts holding not more than £100 and already in existence before 6 October 2020 are excluded. 
  • Will Trusts - excluded from registration for two years from date of death. If it is still in existence after that date or if at any point property is added from outside the estate, it will need to register from that date.
  • Trusts set up under intestacy rules and Personal Injury Trusts set up under a court order to receive compensation. Trusts which weren’t set up via specific instructions from a Settlor.
  • Trusts for bereaved children under 18, and 18-25 trusts where a parent has died
  • Co-ownership trusts set up to hold shares of property or other assets which are jointly owned by 2 or more people for themselves as ‘tenants in common’
  • Charitable Trusts

What information is required?

If the trust does not fall into one of the exempt categories, you will be required to add certain information onto the portal. This includes, but is not limited to:

  • Details of the settlors
  • Details of the trustees
  • Details of the beneficiaries
  • Details of the trust’s assets

For some individuals, in the above groups, you may need to enter detailed information, such as National Insurance Numbers, date of birth, contact details and country of nationality.

When do I need to register the trust? 

HMRC have stated that trusts not falling into an exemption category, have until 1 September 2022 to register with the service. 

From 1 September 2022 onwards, newly created trusts will have 90 days from the date of creation to enter their details on the portal. 

For trusts created close to the deadline, there is a little grace. HMRC have confirmed, in effect, that new non-taxable trusts will have the later of 90 days from creation, or 1 September 2022, to register. 

Once created, the online record then needs to be reviewed/updated annually. 

Whose responsibility is it to register? 

The responsibility for the registration of a trust lies solely with the trustees themselves. If they do not comply with the regulations, they may subject to a penalty fine. 

When a trust is registered, you will receive a record of this registration, and a reference number. 

Financial Advisers (and other financial service providers), will then require this, as proof of registration, before conducting any new business with the trust. 

If you are a trustee, Lovewell Blake Financial Planning Limited want you to be fully aware of your responsibilities, so that if not exempt, you can ensure your trust is registered before the deadline.

Should you require further guidance, it may be that we are able to provide some assistance to you and arrange some help with the registration process. Lovewell Blake LLP offer additional trust administration services too. 

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