We summarise the April 2025 update so trustees can act with confidence. The notice replaces domicile-based rules with residence-based systems from 6 April 2025. That change in tax rules affects how estates are reported and how income from overseas is treated.
We will explain the practical steps in plain English. Expect clear guidance on record-keeping, online services and reporting across the year. Our focus is on everyday administration, not specialist planning.
We know trustees often face the same pain points: unclear responsibilities, missing documents and uncertainty about online declarations. This piece is organised so you can find the section you need, whether managing a family trust or a complex estate.
Throughout, we give practical steps and simple explanations. For help with registering duties, see our advice on registering a trust as an agent.
Key Takeaways
- Major reform from 6 April 2025 moves to residence-based tax rules.
- Trustees must improve record-keeping and access to online services this year.
- We focus on practical, trustee-first guidance rather than legal jargon.
- Common pain points are responsibilities, missing paperwork and online filings.
- Read the section relevant to your role — family or complex administration.
April 2025 reforms trustees need to know about
From 6 April 2025 the tax landscape shifts as the government replaces domicile tests with a residence-based approach. This change affects both inheritance tax and the treatment of foreign income.
What the shift means in practice
The move is more than a technical tweak. It can pull certain trusts and estates into the UK tax net earlier than before. UK-resident trustees who manage overseas bank accounts, shares or foreign property may see new UK tax touchpoints.
Who is most exposed
We expect trustees with non-UK family links or cross-border assets to be most affected. If a settlement has overseas assets, trustees should assume closer UK scrutiny and act now.
- Gather settlement deeds, recent statements and valuations for assets.
- Confirm residency records and beneficiary addresses.
- Review reporting duties and make sure systems can meet payment deadlines.
If a trust could gain UK exposure, seek early advice, tighten records and plan cash flow to pay tax on time.
hmrc trusts and estates newsletter: key compliance actions for trusts and complex estates
Trustees need a clear checklist to navigate recent registration and reporting changes.
What is live now
Trust Registration Service and 5MLD extension
The micro-service is the live route for registration after the old iForm closed in 2020. The 5MLD extension means some registrations remain phased as systems improve.
Registering and moving from the old iForm
If you have an unfinished registration, complete missing details on the micro-service. Keep a copy of deeds and ID ready for any query.
Updating TRS details: people vs assets
Update the register for changes to people linked to the trust — trustees, beneficiaries, settlors, protectors or controlling persons — when the trust was liable to relevant taxes.
Do not use TRS to log routine asset value changes. HMRC has said assets and values do not need the same frequent updates.
Annual declaration and deadlines
If liable for Income Tax, CGT, IHT, SDLT or similar, complete the online annual declaration even when nothing changed. Confirmations are due by 31 January after the tax year.
SA900 tick box 20.1, closing records and agent access
Use SA900 question 20.1 to confirm TRS updates. Mark a trust as ended on TRS when final distributions and accounts match the deed.
Agents need separate TRS authorisation; 64-8 does not cover registration. Each trust needs an organisation user ID and the invitation must be accepted within seven days to avoid access issues.
| Action | Who | Deadline | Notes |
|---|---|---|---|
| Register on micro-service | Trustees / Agents | As soon as liable | iForm closed 23 Sep 2020; migrate unfinished records |
| Update people details | Trustees | When change occurs | Required when liable to relevant taxes |
| Annual declaration | Trustees | 31 Jan after tax year | Required even if nothing changed |
| Close trust / estate record | Trustees / Personal reps | When administration ends | Align TRS with deed and final accounts |
For how new inheritance rules affect family planning, see our guidance on how the new inheritance tax rules affect your family’s.
Related HMRC updates affecting estates, property and inheritance tax
Day-to-day estate administration has new practical steps we should all note before filing any forms.
IHT clearance, Dropbox and turnaround expectations
New clearance letters replace the old stamped IHT30. HMRC now issues a letter with a unique authorisation code. Keep that letter safe with estate papers as proof of clearance.
Dropbox use is now by exception. Where possible, plan for postal filing of IHT400 or IHT100 unless there is a clear operational reason to request a dropbox slot.
Excluded property and non-domicile checks
Foreign assets remain excluded where the settlor was non-domiciled when the trust was made. Legislation also requires a domicile test when adding assets or moving them between settlements.
When transferring assets, the original settlor must be non-domiciled both at creation and at transfer. Missing that check can trigger an unexpected IHT charge.
CGT on UK residential property and relief changes
Personal representatives must report and pay CGT within 30 days of completion for UK residential property. You can use the CGT property service without TRS, but a complex estate may need a UTR obtained via TRS.
Budget update: agricultural and business property relief rises to £2.5 million from April 2026. That shift may help family farms or small companies avoid forced sales to meet a tax payment.
- Practical step: file for clearance early and keep records.
- Check domicile before adding foreign investments or land.
- Plan cash or finance options to meet short-term pay tax dates.
For further official updates see the government bulletin, or read our local inheritance tax planning guidance for practical steps.
Conclusion
With new rules now in place, straightforward routines will keep trustees on top of duties.
Keep calm and stay organised. Treat compliance as protection for the family, not a box-ticking task. Check people details on the register and keep a clear file of decisions and distributions.
Before the next tax year, diarise key dates. Confirm agent access to the online system and chase bank statements early to avoid delayed information.
Common issues include access problems, late documents and uncertainty on reporting routes. You reduce risk by preparing sooner and briefing every decision-maker so the client experience runs smoothly.
Systems change. Keep records current each year and you will avoid last-minute pressure.