We will guide you, step by step. This short introduction explains why you may need to use the Trust Registration Service and how to check if your arrangement needs to be listed. We keep language plain and practical so you can act with confidence.
First, know the difference: to register a trust is not the same as charity registration. You may need to register with HMRC even if no tax is due. That can happen when a Unique Taxpayer Reference (UTR) is required or when anti-money laundering rules apply.
We will show the quickest route to check whether you need to register. We’ll set out the main decision points: is it an express trust, is it excluded, and does it have a UK connection.
Trustees remain responsible for compliance. We explain deadlines, what good looks like for record-keeping, and how to be ready for banks or solicitors that ask for proof.
Key Takeaways
- Use the trust registration service to check requirements quickly.
- Registration is different from charity registration.
- Even non-taxable trusts can need listing for anti-money laundering rules.
- We explain UTR, excluded express trusts and UK connections in plain English.
- Trustees are personally responsible, though advisers can help with the online process.
Understanding what a charitable investment trust is in the UK
A simple way to think of this arrangement is as a legal container that holds assets, managed by trustees for people or causes you want to support. We use plain language so you can see the practical roles and duties.
Key roles in plain terms
Settlor — the person who places assets into the arrangement.
Trustees — the individuals or organisations who run it and make decisions.
Beneficiaries — named people, charities, organisations or a class (for example, “future grandchildren”) who may benefit.
Protector or controller — may oversee trustees and can count as a controller for filing purposes.
Why charity-linked structures still need official listing
Even when a registered UK charity is a beneficiary, the duty to provide beneficial owner information rests on the arrangement’s type and transparency rules. HMRC collects details for settlors, trustees, beneficiaries and controllers.
- Named charity as beneficiary — different to the arrangement itself being exclusively for a registered UK charity.
- Practical impact — banks, solicitors and investment providers often ask for proof of listing before they proceed.
| Role | HMRC details required | Typical duty |
|---|---|---|
| Settlor | Name, date of birth, nationality | Record origin of assets |
| Trustees / Trustee | Personal details and contact | Manage assets, keep records |
| Beneficiary / Beneficiaries | Named or class information | Maintain beneficiary lists and evidence |
For a quick check of whether you must list details, see the government’s guidance on registering a trust. For a practical step-by-step guide to setup and obligations, our team summary is here: unlock the benefits of a UK.
Why HMRC requires trust registration on the Trust Registration Service
We explain why the Trust Registration Service exists and how it helps stop misuse of complex ownership structures.
The core aim is simple: improve transparency and support anti-money laundering controls. The service helps regulators and firms spot risky arrangements early.
Anti-money laundering regulations and transparency duties
Beneficial owners are the people who ultimately benefit or control decisions. HMRC asks for their details so banks and solicitors can satisfy legal checks.
In practice, this matters when you open accounts, move property or deal with investments. Firms will request proof of listing before they act.
“The register exists to increase clarity about who really controls assets, making laundering and other misuse harder.”
When you need a UTR for Self Assessment
A UTR is the trust’s tax identifier. You normally need it to file a trust and estate tax return under Self Assessment.
Important surprise: even excluded arrangements may still require a UTR when there is a tax reporting need or a relief claim. That leads to a requirement to use the TRS.
| Trigger | What you get after listing | Why it matters |
|---|---|---|
| Taxable trust files Self Assessment | Unique Taxpayer Reference (UTR) | Needed to submit returns and pay tax |
| Non-taxable but listed | Unique reference number | Proof for banks and advisers |
| Excluded arrangement with tax report | UTR may still be issued | Registration required despite exclusion |
- We will keep this reassuring: the aim is compliance and record-keeping, not an assumption of wrongdoing.
- After listing expect either a UTR (for taxable cases) or a unique reference number for non-taxable cases.
Does your trust need to register with HMRC?
Start by asking four simple questions about how the arrangement was created and where it connects to the UK. This gives a quick decision route so you can act with confidence.
UK express arrangements vs those that arise by law
Express arrangements are deliberately set up by a settlor, often in a deed or will. These are usually required register on the Trust Registration Service unless a specific exclusion applies.
Non-express arrangements arise automatically, for example by operation of law. Those rarely need listing, but check the exclusions carefully.
Non-UK arrangements with a UK link
Non-UK express cases must register if they buy UK land or property, have a UK-resident trustee, or enter certain business relationships with UK firms.
Even remote activity can trigger a duty. For example, working with UK banks, lawyers or advisers may mean you are required register.
When tax turns an arrangement into a registrable case
Simple investment events can create a tax liability: receiving interest, dividends, rental income or making gains on disposals. If the arrangement becomes liable for UK tax on assets or income, it must be trust registered.
Practical next step: gather the deed and a short list of key people before you start the online process.
charitable investment trust registration hmrc: eligibility checks before you start
Before you start online, a quick eligibility check will save time and prevent needless filings. We walk you through the simple facts to spot whether the arrangement is already taxable or not.
Confirm whether the trust is taxable or non-taxable
First step: check if the arrangement currently receives income, makes gains or holds UK property. If it does, it may be a taxable case and must use the registration service.
Non-taxable trusts can still appear on the register. They may get a reference number rather than a UTR and generally do not file annual trust tax returns.
Check whether it is an excluded express trust (Schedule 3A)
Schedule 3A lists excluded express trusts that do not normally have to register. A common example is a trust set up for a registered UK charity. But exclusions depend on precise facts and timing.
Common excluded categories that may apply
- Will trusts wound up within two years of death.
- Old pilot trusts under £100 set up before 6 October 2020.
- Co-ownership as tenants in common and certain life policy arrangements.
When an excluded trust still has to register
Practical warning: exclusions are not permanent shields. If a later tax liability arises, you will be required register and may need a UTR to file Self Assessment.
“Check both the exclusion rules and any current or future tax exposure before deciding not to register.”
We suggest keeping a short trustee checklist recording your decision, the reasons and key dates. That way you can show why you did, or did not, sign up at a given time.
Tax triggers that make a trust registrable
A single taxable event can suddenly change a trust’s reporting duties and start statutory deadlines. When a liability arises, the arrangement may need to be listed and a tax return filed.
Income tax on income, interest and distributions
Common triggers include bank interest, bond interest, dividends and distributions from collective funds. These types of income often create an immediate income tax liability.
Practical tip: note the date income is received. That date can start filing deadlines.
Capital gains tax on disposals
Selling shares, funds or UK property can create capital gains. A single disposal that produces gains may trigger capital gains tax and a reporting duty.
Keep records of purchase dates, sale dates and values. These details support any claim and help calculate gains tax correctly.
Inheritance tax and estate-related events
Certain estate events can create inheritance tax liabilities. For example, life interest changes or chargeable transfers may start an IHT duty and make the arrangement reportable.
Stamp Duty Land Tax and UK property taxes
Buying UK land or property may trigger stamp duty land tax (or LBTT in Scotland, LTT in Wales). Property transactions often create both a tax liability and a registration trigger.
- One event is enough: any taxable income, gains, inheritance or property tax can make the arrangement registrable.
- Records matter: keep deeds, invoices, valuations and bank statements safe.
- Real life: a trust buys a buy-to-let flat, receives rental income, then later sells at a profit — this creates income tax, capital gains tax and a registration duty.
“Even a single sale or a payment of interest can change your obligations overnight.”
Registration deadlines and key dates trustees must meet
Timetables for filings are straightforward once you know the triggers to watch. We set out the main date rules so trustees can add them to a shared calendar and avoid fines.
The 90-day rule for new cases and new triggers
Key rule: register within 90 days of the trust being created or of a new tax trigger arising.
A new trigger can be anything from buying UK property to receiving taxable income. That restart of the 90-day clock is crucial.
Deadlines for arrangements created before and after April 2021
Historic cut-offs remain relevant. Non-taxable cases created on or before 6 October 2020 had to meet a 1 September 2022 deadline to be listed.
For trusts created before 6 April 2021 and becoming liable to Income Tax or CGT for the first time, the key date is 5 October in the following tax year.
Where the 5 October and 31 January dates apply
- 5 October: first-time liability to Income Tax/CGT for pre-6 April 2021 cases.
- 31 January: applies where a trust already files within Self Assessment, and generally for other taxes following the tax year of liability.
Updating the register: 90-day updates vs annual confirmations
Non-taxable trusts must update details within 90 days of becoming aware of a change. Taxable trusts often have annual confirmations by 31 January.
Practical tip: add all these dates to a shared calendar and assign responsibilities so trustees do not assume someone else will act.
“Trustees should treat date reminders as part of good governance — it protects beneficiaries and avoids penalties.”
For help with agent steps and managing deadlines, see our agent guidance.
What information you’ll need to register a trust
We’ll keep this simple. Gather the right papers before you start the online process to avoid timeouts and repeated entries.
Trust basics to have ready
Trust details: name, creation date and whether it was set up as an express arrangement. HMRC also asks if there is a UK business relationship for non-UK cases and whether any UK land or property has been bought.
Lead trustee — the main contact
Individuals must supply name, date of birth, national insurance number (if UK), address, telephone, nationality and country of residence. Non-UK individuals give passport details instead of an NI number.
Organisations acting as lead trustee need their name, UTR, contact details and country of residence.
Settlor information and sensitive prompts
Enter settlors’ names and dates of birth. For living settlors, HMRC will ask about mental capacity. We recommend noting capacity sensitively and factually. The system assumes capacity unless you state otherwise.
Capturing beneficiaries
List named beneficiaries and classes (for example, “future grandchildren”) clearly. For employment-related groups, state the employer and the class definition. Accurate beneficiary entries reduce follow-up queries.
UK land and property details
If the arrangement owns UK land, have addresses, purchase dates and values ready. HMRC requests purchase specifics even when the arrangement’s main purpose is to support a cause. This helps show any UK connection.
“A short checklist before you log in saves time and avoids repeated edits.”
- Checklist: deed or will, ID for lead trustee(s), settlor details, beneficiary list, land deeds or property addresses.
- Keep digital copies to hand so you can complete the form in one session.
- If you need step-by-step help, see our concise guide to getting set up: registering a trust in Britain — our step-by-step.
Extra information required for taxable trusts
If a tax liability arises, expect extra questions about the type of arrangement and the assets it holds.
What changes when a case is taxable: the form asks for the arrangement’s type, how it was set up, and any Unique Taxpayer Reference (UTR) if you already have one. You must also say if Schedule 3A applies only where a UTR is needed to report liability.
Type and origin
Describe the type clearly. Use the deed or will language where possible. Note whether decisions are made by named individuals or an organisation.
Values for money, shares and business interests
Give approximate totals for cash and bank balances at registration. For shares, include company name, number of shares, class/type and an estimated value at registration.
Property, land and partial ownership
Enter property addresses and an estimated full value. Say what portion the arrangement holds — for example, 50% of a house. Partial ownership affects capital gains and land taxes.
Controlling interests in overseas companies
If the arrangement controls a company outside the EU/EEA, provide the company name, address, governing law and the date control began. This helps the tax authority spot potential changes in ownership or gains.
“Keep a short valuation note explaining how you arrived at each figure — it helps if anyone queries your entries later.”
| Asset category | Details required | Example entry | Reason |
|---|---|---|---|
| Money | Total cash balance and currency | £12,500 — bank accounts | Shows liquidity and income potential |
| Shares | Company name, number, class, approx value | Acme Ltd, 1,000 A-class, £8,000 | Affects capital gains and dividends |
| Business interests | Business name, address, description, approx value | Smith Farm Ltd — trading, £40,000 | May create trading or rental income |
| Property / land | Address, full value, percentage held | 12 High St, £250,000, 50% | Key for SDLT and capital tax calculations |
Practical tip: keep concise valuation notes and copies of deeds or recent valuations. That small file saves time and protects beneficiaries if values or gains are later questioned.
How to register your charitable investment trust using HMRC’s online service
Start the process by creating the correct type of Government Gateway account for your trust. Use an Organisation account — an Individual account will not work.
Create an Organisation Government Gateway account (not an Individual account)
HMRC requires an Organisation Government Gateway user ID and password. You will need an email linked to that Organisation account, your full name and a phone number.
Using a separate Government Gateway ID for each trust you manage
HMRC asks for a different Organisation ID for each arrangement you handle. This keeps records clear when you manage more than one.
Completing the Trust Registration Service submission without delays
Gather key details before you start. Have the deed, names and addresses of settlers and trustees, beneficiary info and any property data ready.
- Lead contact: choose and agree who will act as lead trustee.
- Login basics: dedicated trustee email, phone number and a secure password.
- Form order: trust details first, then people, then assets and tax answers.
“Save a copy of what you submit — you will need it for updates and as evidence when dealing with banks or advisers.”
After registration: what you receive and what to do next
After you click submit, your next actions matter as much as the form itself. We explain what success looks like and which documents to save.
When a UTR arrives and how to use it
For taxable trusts: the lead trustee usually receives a Unique Taxpayer Reference within 15 working days. Use this UTR to start filing Self Assessment and to talk to advisers about tax returns.
Getting the unique reference for non-taxable cases
For non-taxable trusts: log back into the service after submission to retrieve the unique reference number. This number proves the arrangement is trust registered for non-tax purposes.
Downloading proof for new business relationships
Trustees can download a PDF by choosing “Get evidence of the trust’s registration”. Banks, investment firms and solicitors often ask for this when forming new business relationships.
Authorising an agent
You can authorise an accountant or adviser to view and update details. Remember: trustees remain responsible, so keep a copy of any authorisation and the latest submission.
- Simple admin routine: store the UTR or reference, save the evidence PDF, and note the submission date.
- Refresh the PDF if you update information before sharing it with third parties.
Keeping the trust registered and compliant over time
Keeping your entry up to date is an ongoing part of trusteeship, not a one-off chore.
We recommend a simple routine. Check details after any major life event. Update promptly so records stay accurate.
What changes must be reported and when
Reportable changes commonly include new or resigned trustees, beneficiaries becoming known, changes to lead contact details and shifts in who controls decisions.
Non-taxable cases must be updated within 90 days of trustees becoming aware of a change.
Taxable cases also need an annual confirmation by 31 January after the tax year, plus 90-day updates for event-based triggers.
Maintaining accurate beneficial owner information
Beneficial owner information means the facts that show who benefits or controls the arrangement.
- Nationality and country of residence for each individual.
- Nature and extent of a beneficiary’s interest (named or class details).
- Any change in control or decision-making powers.
“Keep contact details for the lead trustee up to date — it helps when firms ask for proof of being trust registered.”
Consequences and practical tips
HMRC may charge a penalty of up to £5,000 for failure to register or to keep entries current. That is a real risk trustees should avoid.
Practical tips: agree who monitors changes, keep a secure shared file of documents, and log updates with dates and reasons.
| Change | When to update | Why it matters |
|---|---|---|
| Trustee appointments / resignations | Within 90 days | Shows who is responsible for decisions |
| Beneficiary details become known | Within 90 days | Records who benefits and any tax effects |
| Lead trustee contact details | As soon as possible | HMRC and firms use this to contact the lead |
| Change creating tax liability | 90 days or annual confirmation (as applicable) | May trigger filing and a UTR requirement |
Protecting beneficiaries and handling information sharing
We guide you through when information can be shared and how to shield beneficiaries from harm.
When data may be disclosed under the Money Laundering Regulations
The service may release details in narrow cases. This happens when an authorised body shows it is investigating money laundering or terrorist financing linked to a specific arrangement.
What can be shared: full name, month and year of birth, nationality, country of residence and the beneficial interest held.
Reporting a disproportionate risk of harm
Trustees can email trs.riskofharm@hmrc.gov.uk with subject line “Beneficial owners at risk of harm”.
- Include the UTR or unique reference number and the arrangement name.
- Name the lead trustee and which beneficiaries are at risk.
- Briefly state the specific risk (fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation).
- Give clear reasons, how long the risk will last and contact details for follow-up.
How the authority reviews notifications and the 12‑month assurance
They assess your email and may apply an exemption that limits disclosure. If granted, the assurance lasts 12 months from the date received.
Renew annually if the risk continues and diarise the renewal date so beneficiaries stay protected.
“Describe the danger clearly but avoid sharing unnecessary personal details in your initial message.”
Conclusion
To conclude, we urge a practical, calm approach.
If the arrangement is an express one, has a UK link, or faces a UK tax trigger, you may need to register. Check Schedule 3A exclusions, confirm whether it is taxable, then follow the correct deadline.
Done properly means a clear lead contact, accurate beneficiary records and a plan for timely updates. Keep copies of deeds, ID and proof of filing.
After you submit you will receive either a UTR or a unique reference number. That proof helps when banks or advisers ask for evidence of trust registration.
Where matters are complex — property, overseas companies or tax questions — seek professional help. Staying organised protects the aims, the family and the trustees personally.