MP Estate Planning UK

Trust Record-Keeping Requirements for HMRC Compliance

trust record keeping documents hmrc

We help trustees manage the paperwork that keeps a family arrangement clear and compliant. This short guide explains what to save, why it matters and how good organisation protects beneficiaries.

HMRC guidance lists core items to keep: bank statements, interest confirmations, National Savings papers, insurance certificates, dividend vouchers, broker reports, expenses and tax proofs. We set out these items in plain English so you can meet today’s compliance standards without fuss.

Keeping clear documentation is part of a trustee’s duty under law. Good records make tax reporting and trustee accounts straightforward and cut the risk of family disputes.

We introduce the Trust Registration Service, show practical filing tips and give a simple example of reconciling interest and dividends. For help on registration see our advice on registering with the TRS.

Key Takeaways

  • Save bank, tax and investment papers to support yearly accounts.
  • Organised documentation reduces disputes and eases tax filings.
  • Registration with the TRS makes accurate information more important.
  • Trustees have a legal duty to keep clear details of payments and beneficiaries.
  • Practical systems save time at the filing deadline and protect the estate.

What HMRC, TRS and UK law expect from trustees now

A straightforward system for who is involved and what is held stops delays with providers.

Good information matters for tax and for clear trustee accounts. Accurate facts make year-end filings smoother. They also reduce family disputes by showing what happened and why.

The Trust Registration Service has changed the old “file it away” habit. Registration often means providers and companies will ask for names, roles and valuations before they deal with a trust. Missing details can delay investments or banking.

Legal duties under the Money Laundering Regulations 2017

Regulation 44(1) requires written, accurate and up-to-date notes of beneficial owners. This covers settlors, trustees, beneficiaries and anyone with control, plus paid advisers. “Accurate and up to date” means updating information after major life events.

  • Why this matters: helps with tax compliance and shows who has influence.
  • What is typically requested: names, dates of birth, addresses and adviser details.
  • When to update: marriage, death, a move abroad, or changes in entitlement.
RequirementSourcePractical effect
Beneficial owner detailsRegulation 44(1)Must keep written, accurate and current records
Registration data for TRSTrust Registration ServiceNeeded for providers; missing data delays new accounts
Tax filings and trustee accountsHMRC expectationsClear facts support correct tax returns and accounts

A modern office setting, filled with natural light from large windows. In the foreground, a diverse group of professional individuals in business attire, focused on a digital tablet displaying a detailed dashboard of trust registration service information. The middle features a wooden conference table cluttered with legal documents, laptops, and a sleek projector displaying charts and compliance guidelines. In the background, a large whiteboard with diagrams illustrating trust record-keeping requirements is partially visible. The overall atmosphere conveys diligence and professionalism, emphasizing the importance of compliance with HMRC regulations. The lighting is bright and warm, reminiscent of a productive work environment, with a slight depth of field effect to draw attention to the foreground interactions.

For practical steps on registration and what to have ready, see our guide on registering as a trustee. We keep the process simple and jargon-free.

trust record keeping documents hmrc: the core records every trustee should keep

A concise ‘core pack’ of files makes annual filings and beneficiary queries far easier.

We suggest a simple folder that holds the essentials. Keep both paper and digital copies where practical.

A close-up view of a neatly organized desk featuring an array of trust record-keeping documents related to HMRC compliance. In the foreground, a stack of neatly arranged folders labeled with terms like "Trust Deeds," "Accounts," and "Minutes," showcasing colorful tab dividers. A polished wooden desk provides the middle ground, with an elegant pen and a calculator beside the folders. In the background, a soft-focus bookshelf filled with law and finance books creates a professional atmosphere. Natural light streams in through a window, casting warm highlights across the documents. The entire scene conveys a sense of order and professionalism, essential for every trustee maintaining accurate records.

Bank statements, interest confirmations and National Savings papers

Keep current and deposit bank statements and any confirmations showing interest paid.
Include NS&I or National savings certificates and receipts. These prove income and help reconcile accounts.

Insurance and investment paperwork

Save chargeable event certificates from insurers and dividend vouchers for shares, OEICs and unit trusts.
Retain stockbroker reports that show buys, sells and any income paid to the funds held.

Expenses, payments and taxes paid

Record professional fees, bank charges and property costs. Note dates, amounts and who authorised each payment.
Keep evidence of all taxes paid so you can show how sums were settled.

Income paid to beneficiaries and forms R185

For discretionary arrangements, log who received income, when and how much. This helps complete trustee accounts and tax returns.
Use form R185 (Trust Income) for beneficiaries who need details for self assessment or repayment claims. Keep a copy of every R185 issued.

When to use form R185 (Settlor)

Use the R185 (Settlor) where the settlor — or their spouse/civil partner — retained an interest.
File a copy so future queries are simple to answer.

Governance and trustee decisions

Keep minutes of meetings, deeds of appointment and any written decisions that affect capital or income.
Clear governance files reduce disputes and show why decisions were made.

ItemWhy keep itExample
Bank statements & interest confirmationsProve income and balance with accountsCurrent account statements; NS&I interest slips
Chargeable event & dividend vouchersSupport tax calculations on gains and incomeInsurer certificate; company dividend voucher
Expense records & tax paymentsShow allowable costs and evidence paymentsInvoice from solicitor; tax payment receipt
R185 formsHelp beneficiaries claim relief or complete returnsR185 (Trust Income) and R185 (Settlor) copies
Minutes & deedsDocument decisions affecting capital or incomeMeeting minutes; deed of appointment

Records you must keep when the trust buys, sells or receives assets

When assets move in or out, a clear paper trail makes future tax and accounts simple.

Why asset events need their own file: they often drive capital calculations, income reporting and questions from advisers. Good files cut accountant time and reduce the risk of errors.

A well-organized office workspace featuring neatly stacked property asset records, including folders, papers, and binders, arranged on a polished wooden desk. In the foreground, a close-up of a binder open to display charts, graphs, and detailed documents related to asset transactions. The middle ground showcases a laptop with a spreadsheet visible, surrounded by a calculator and pens. The background reveals a large window allowing soft, natural light to illuminate the scene, casting gentle shadows. The mood is professional and organized, emphasizing clarity and compliance. The setting conveys an atmosphere of diligence and responsibility in trust record-keeping, suitable for adherence to HMRC regulations. No human figures are present in this workspace.

Property transactions

Keep completion statements, solicitor invoices and estate agent fees. Include clear evidence of Stamp Duty Land Tax paid.

These items show purchase costs, sale proceeds and allowable expenses when calculating gain or loss.

Shares and funds

Save contract notes, broker statements and proof of any capital movements in or out of funds.

These papers explain dates, prices and fees when shares are sold or bought.

Additional assets paid into the trust

Note the market value at the transfer date, the date received and who provided the asset.

Who provided it matters where family members or companies contribute money or investments.

Let property records

Keep mortgage interest statements, annual bills (for example water or business rates) and tenancy or licence agreements.

These show rent received, costs paid and help when completing accounts and taxes.

  • Practical tip: keep receipts for sale and purchase expenses so net proceeds are clear.
  • Real-life frame: selling a family home or buying a buy-to-let is far easier to explain with this pack.
  • For support: see our guidance on registering a trust and official advice on record keeping for tax.

Keeping TRS and beneficial owner information accurate and up to date

Accurate personal and corporate identifiers are the practical backbone of registration and compliance. We set out what to hold and when to update it so lead trustees can act with confidence.

A modern office setting emphasizing the concept of "beneficial owner information" for compliance. In the foreground, a focused business professional in formal attire inspects documents on a sleek desk, highlighting stacks of papers with graphs and charts. The middle layer features an open laptop displaying a spreadsheet of beneficial owner details, with soft light reflecting off the screen. The background shows a glass wall with a city skyline, bathed in warm afternoon light, creating a productive atmosphere. The mood is serious yet organized, reflecting the importance of maintaining accurate records for HMRC compliance. The composition includes a slight depth of field, emphasizing the subject while softly blurring the background elements.

Contact details for trustees and paid advisers

Keep a clear contact list for trustees and any paid advisers. Include full name, role, address and a phone or email for quick contact.

Individuals

Record full name, date of birth, National Insurance number and current address. For non-UK addresses add passport or ID details (number, country of issue and expiry date).

Companies

Note company name, UTR, registered office, legal form, governing law and Companies Register reference. This helps when a corporate trustee or beneficiary is involved.

Classes, express specifics and lead trustee duties

Write classes of beneficiaries clearly. For example: “all grandchildren of Sarah Thompson”. Keep the trust name, creation date, tax residence and place of administration on file.

ItemWhat to includeWhen to update
IndividualsName, DOB, NI or passport, addressChange of address, name or nationality
CompaniesName, UTR, registered office, Companies Register IDReorganisation or change of office
ExemptionsShort note of decision and the legal basisWhen deciding not to register or relying on an exemption

Quick checklist: update after a change of trustee, beneficiary death, address change or company restructure. If you need more practical guidance, see our unlock the benefits of a UK.

Conclusion

Simple, regular habits cut the time trustees spend on year-end accounts and compliance. Keep a clear paper trail that supports tax returns, trustee accounts and confident decisions across the life of the trust.

Must keep legal items include beneficial owner details for registration and service checks. Day-to-day items to save are bank, investment and expense papers so trustees can explain money flows and meet their duty.

Our practical habit: save statements monthly, file new investment and insurance papers as they arrive, and write decisions up while they are fresh. If there is no business income, keep records until one year after the 31 January filing deadline (for example, keep a 2023–24 return pack until 31 January 2026).

Where assets are complex, tidy your core files, check TRS and beneficial owner entries, and ask for professional advice. Good organisation protects beneficiaries and makes running trusts simpler year after year.

FAQ

What are the basic record-keeping duties trustees must follow under UK law?

Trustees must keep clear, dated records of decisions, money in and out, and the assets held. That includes minutes of meetings, deeds of appointment, bank statements, and any paperwork showing how capital and income are dealt with. Trustees also need to hold evidence of payments made to beneficiaries and any tax paid. These records help with compliance, protect beneficiaries’ interests and make it easier to respond to HMRC or legal queries.

Why do proper records matter for tax, trustee accounts and disputes with beneficiaries?

Good records show what was intended and what was done. For tax returns and trustee accounts they prove income, gains and allowable expenses. If beneficiaries question a decision, minutes and supporting invoices explain the trustees’ reasoning. Clear files reduce the risk of penalties, lengthy challenges and unnecessary legal costs.

How does the Trust Registration Service (TRS) change the old “file it away” approach?

The TRS means trustees must provide defined details about the trust and its beneficiaries online. It moves trusts from private filing towards formal registration and ongoing updates. Trustees must keep the online data accurate and save evidence that supports what was registered, such as identity documents and proof of address for beneficiaries or trustees.

What specific duties do trustees have under the Money Laundering Regulations 2017 (Regulation 44(1))?

Trustees who carry out regulated activities must apply customer due diligence, keep records of the checks they make, and be able to produce those records on demand. This includes identity verification for settlors, trustees and beneficiaries where applicable, and keeping evidence of any risk assessments or enhanced checks.

Which core records should every trustee keep for HMRC purposes?

Keep bank statements and interest confirmations, National Savings records, insurance and investment paperwork such as chargeable event certificates and dividend vouchers, plus broker reports. Also retain records of expenses paid by the trust, tax receipts, and clear notes showing income distributed to beneficiaries and why those sums were paid.

What paperwork should trustees keep for insurance and investment holdings?

Hold contract notes, annual statements, chargeable event certificates, dividend vouchers and any correspondence with insurers or fund managers. These documents prove dates, values and tax events, and help calculate capital gains or income due to beneficiaries.

How should trustees record trust expenses, payments and taxes paid?

Keep dated invoices, receipts and payment confirmations. Note the purpose of each payment, who authorised it and which trust fund (capital or income) was affected. Retain copies of tax returns, payment slips and correspondence with HMRC to show taxes were correctly reported and paid.

When must trustees use form R185 and when is a R185 (Settlor) needed?

Form R185 is used to report trust income paid to beneficiaries so PAYE can be applied where relevant. R185 (Settlor) applies when income is treated as the settlor’s for tax. Copies of both forms and related correspondence should be kept to show why PAYE or settlor treatment was used and to support future tax enquiries.

What trustee decision records are essential?

Keep minutes of meetings, written consents, deeds of appointment or retirement, and formal resolutions affecting capital or income. Record who attended, the decisions made, relevant legal or professional advice and any conflicts of interest declared.

What documents are needed when a trust buys or sells property?

Keep completion statements, solicitor invoices, estate agent fees and Stamp Duty Land Tax (SDLT) papers. Also keep survey reports, exchange documents and any correspondence about who authorised the purchase or sale and how funds were moved.

Which records apply to shares and funds transactions?

Save contract notes, settlement confirmations, dividend vouchers and broker reports showing purchase and sale dates, prices and any charges. These support capital gain calculations and trace where funds moved into or out of the trust.

How should trustees document assets added to the trust?

Record the asset description, value on the date of transfer, the date received and the person who provided it. Where relevant, include valuation reports, transfer paperwork and any tax advice obtained about the transaction.

What paperwork is needed for let property held by a trust?

Keep tenancy agreements, rent receipts, mortgage interest statements, annual utility and maintenance bills, inspection reports and records of repairs. These show income and allowable expenses when preparing accounts and tax returns.

What details must trustees keep up to date on the TRS about trustees and advisers?

Maintain current contact details for trustees and paid advisers, including names, addresses and professional identifiers. Promptly update the TRS when trustees or advisers change to keep the register accurate.

What personal information is required for individual trustees and beneficiaries?

Record full name, date of birth, National Insurance number and current address. For non-UK residents, retain passport or ID details and proof of address. Keep these securely and only share when required for registration or legal checks.

What company identifiers are needed for corporate trustees or corporate beneficiaries?

For companies keep the UTR, registered office address, legal form, governing law and Companies House registration details. Also note directors’ names where relevant. These details confirm legal identity and help with tax and compliance checks.

How should trustees describe classes of beneficiaries?

Use clear, identifiable descriptions rather than vague language. State groups by relationship or defined criteria, such as “children of X born before Y date,” to ensure beneficiaries can be identified for distribution and TRS reporting.

What express trust details must be recorded for registration and compliance?

Record the trust name, creation date, country of tax residence, place of administration and the trust’s purpose. Keep the governing document and any deeds that affect how the trust operates.

What records should a lead trustee keep about roles and identifiers?

Note who the lead trustee is, each trustee’s role, their identifiers (NI number or passport/passport details), and contact addresses. Keep evidence of appointments and any decisions assigning lead duties.

How do trustees document exemptions or decisions not to register on the TRS?

Where an exemption applies, keep a written record explaining the legal basis and any supporting evidence. Save correspondence with advisers and any legal opinions that justify not registering, in case HMRC asks for proof.

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