MP Estate Planning UK

HMRC Trust Tax Registration Requirements Explained

hmrc register trust tax

We walk you through what it means for most family arrangements to appear on the national trust registration list. This is simple, practical guidance written for people acting as trustees.

Most UK trusts must be recorded on the trust registration service unless an exemption applies. Trustees are legally responsible for this step. It also supports anti-money laundering rules and can help when a Unique Taxpayer Reference is needed for Self Assessment.

We will explain what “hmrc register trust tax” means in everyday terms. We show who this guide is for and how rules changed when a trust doesn’t pay tax.

Expect clear steps on what you do online, how long it takes and what you receive afterwards, such as a URN or a UTR. We also point to exemptions, deadlines and what information you need to keep records up to date.

For further detailed help from our team, see our expert guidance on registering a trust as an.

Key Takeaways

  • Most family and will arrangements need trust registration unless exempt.
  • Trustees carry the legal duty to ensure registration is completed.
  • Registration serves AML checks and may produce a UTR for Self Assessment.
  • The process is generally online; you will get a reference number afterwards.
  • We will cover exemptions, deadlines and the exact information you will need.

Understanding the HMRC Trust Registration Service and why registration exists

Think of the service as a simple online ledger where trustees note who is involved and what the family arrangement owns. We use it to make the people and assets clear to the government and to firms that need proof of transparency.

A professional office setting illustrating the concept of a "trust registration service." In the foreground, a diverse group of three professionals in business attire engage in a discussion around a sleek conference table, with documents and a laptop displaying charts related to trust registration. The middle ground features a modern whiteboard filled with organized notes and flowcharts regarding HMRC regulations. In the background, large windows allow soft, natural light to illuminate the room, creating a bright, productive atmosphere. Use a wide-angle lens to capture the collaborative environment, with a focus on the professionals' engaged expressions. The mood is serious yet hopeful, conveying the importance of efficient trust registration.

Anti-money laundering purpose

The registration service supports anti-money laundering checks. Banks, solicitors and other relevant persons may ask for evidence that the arrangement appears on the online list before they act.

Who counts as a beneficial owner and key roles

A beneficial owner can be a settlor, trustee, beneficiary, protector or any person with control. Getting these roles right saves time when you enter information online.

  • Settlor — the person who set the arrangement up.
  • Trustee(s) — those who manage assets; all are responsible.
  • Lead trustee — the main point of contact for the registration service.

For a clear walkthrough and practical steps from our team, see our guide for trustees.

Do you need to register a trust with HMRC?

A clear first step is to check whether your arrangement will ever face a UK tax charge. That helps you decide if you need to register trust details before spending time on the online service.

Who must register because they are liable for UK tax

You must register when the arrangement becomes liable for Income, Capital Gains, Inheritance, Stamp Duty Land Tax or Stamp Duty Reserve Tax. If a UTR is needed to file Self Assessment, that creates a registration trigger too.

A professional office setting depicting a diverse group of individuals engaged in a discussion around a table, examining documents related to trust registration. Foreground features a close-up of hands pointing to a trust registration form, emphasizing important details. In the middle, a diverse team of two women and two men, dressed in smart business attire, are actively discussing, with expressions of concentration and concern. The background shows a large window with natural light streaming in, illuminating a modern office space with plants and charts on the walls, conveying an atmosphere of productivity and seriousness. The mood is focused and professional, capturing the essence of financial responsibility and trust management.

Non-taxable UK express trusts that still need registration

Many express trusts set up by deed or a will must appear on the public ledger even if they currently owe no charge. This is to satisfy anti-money laundering checks and to help banks or solicitors verify details.

Non-UK express trusts with UK connections

Overseas arrangements can be caught. Registration becomes necessary if the trust acquires UK property or if a UK-resident person starts a UK business relationship on behalf of the arrangement.

Quick decision framework

  • Does the arrangement produce income (rent, interest, dividends) or gains (sale of property or shares)? If yes, register.
  • Is a UTR required for Self Assessment? Register.
  • Is the arrangement an express trust created by deed or will? Likely register unless excluded under Schedule 3A.
SituationExampleRegistration needed?Reason
UK buy-to-letProperty lets producing rental incomeYesIncome and capital gains potential
Savings and sharesInterest or dividends held by the arrangementYesIncome triggers and Self Assessment UTR
Overseas will trustNon-UK trust buys UK landYesUK property connection

Excluded trusts and Schedule 3A exemptions you should check first

Start by seeing if the arrangement falls into a Schedule 3A exclusion; this saves time and worry. We check exclusions first because they can free you from needless administration.

A professional and elegant office setting, featuring a large wooden desk in the foreground with stacks of financial documents and a tablet displaying charts. In the middle, a diverse group of three individuals dressed in professional business attire—two men and one woman—collaborate over the paperwork, examining trust exemption criteria. In the background, a bookshelf filled with legal texts and tax guides adds depth, while a large window bathes the room in natural light, creating a warm and inviting atmosphere. The image captures a sense of focus and collaboration, emphasizing the importance of understanding excluded trusts and exemptions, with soft lighting to enhance the professional mood.

Common exclusions include will arrangements that end within two years of death and simple co-ownership where people hold property as tenants in common. These are typical situations we see for family estates.

Low-value and purpose-based exemptions cover pilot trusts set up before 6 October 2020 with under £100, child bank account arrangements, and similar small-purpose set-ups. They relieve many ordinary family arrangements from full registration.

Pension and insurance exclusions also apply. UK registered pension scheme arrangements and certain life-insurance policies that only pay on death, illness or disability fall outside the AML list.

The important catch: an excluded arrangement still needs registration if it becomes liable for UK tax or requires a Unique Reference Number for Self Assessment. Keep a short written note of which exemption you rely on and why. For step-by-step official guidance on related registration matters see our guidance on trust registration.

Registration deadlines and ‘within days’ rules trustees must follow

Deadlines matter: missing a key date can trigger penalties and extra work for those managing family arrangements.

Historic cut-off for older non-taxable arrangements:

Non-taxable arrangements created on or before 6 October 2020 had a one-off deadline. They needed to be on the online list by 1 September 2022. If you met that date, you are set for that specific rule.

A professional office environment, featuring a large wooden desk cluttered with paperwork and files related to tax registration. In the foreground, a focused middle-aged man in a crisp business suit is reviewing a calendar marked with important registration deadlines, highlighting urgency. The middle ground shows a soft-focus bookshelf filled with tax guides and regulation books, depicting a sense of thoroughness. In the background, large windows allow natural sunlight to stream in, casting gentle shadows across the room, creating a productive atmosphere. The lighting is warm and inviting, suggesting a sense of urgency yet professionalism. Include a wall clock showing time ticking down, enhancing the theme of imminent deadlines without any text in the image.

Newer non-taxable arrangements

For non-taxable arrangements created after 6 October 2020 the rule is simple. You must complete registration within 90 days of creation or within 90 days of ceasing to be excluded. That means acting within days when circumstances change.

When a charge arises

Deadlines for arrangements that become liable vary by the type of liability.

  • For arrangements created on or after 6 April 2021, register within 90 days of becoming liable.
  • For older arrangements with a first-time income or capital gains liability, register by 5 October in the following tax year.
  • If the arrangement has been liable before, the deadline is 31 January following the tax year.
  • Other liabilities also use the 31 January deadline in the following tax year.

Practical rule: when more than one date applies, the earlier deadline wins. Set reminders for 90-day windows and the 5 October / 31 January dates.

SituationDeadlineWhen it applies
Non-taxable, created on/before 6 Oct 20201 Sep 2022Historic fixed cut-off
Non-taxable, created after 6 Oct 2020Within 90 daysFrom creation or end of exclusion
Taxable, created on/after 6 Apr 2021Within 90 daysFrom becoming liable (income / gains)
Older trusts with first-time income or capital gains5 Oct (following tax year)First-time liability for income or capital gains
Previously liable or other taxes31 Jan (following tax year)Ongoing or other tax liabilities

Tip: build a simple trustee calendar. Add 90-day alerts and the key 5 October and 31 January dates. This small step keeps the arrangement compliant and avoids late filings and stress.

What you’ll need before you start the registration service application

Before you log in, gather the core information so the process is quick and accurate. Small mistakes can cause delays later, so a short checklist saves time and stress.

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Trust basics to have ready

Prepare the arrangement’s full name and the creation date. Confirm whether it is an express trust by checking the deed or will.

Lead trustee details

Nominate a lead trustee and collect their identity details. For UK citizens include date of birth, National Insurance number and current address. For non-UK nationals use passport details, nationality and country of residence.

Settlor, trustees and beneficiaries

List settlor and trustee names and contact details. Record beneficiaries as far as they are known. If some beneficiaries are unnamed, explain their class (for example “future grandchildren”).

Assets and values to prepare

Note approximate values for property, shares, cash and other valuables such as jewellery or art. HMRC asks for rounded figures to help with anti-money laundering checks and practical record-keeping.

Quick paperwork checklist

  • Arrangement name and creation date
  • Lead trustee identity, contact, nationality and residence
  • Settlor, other trustees and beneficiaries’ details
  • Asset categories with approximate values
  • Copies of deed or will to confirm express status

Tip: small mismatches — a misspelt name or an old address — can slow future changes. Double-check entries before submission.

ItemWhy it mattersExample detail
Arrangement nameUnique identifier for online recordsSmith Family Settlement
Creation dateDetermines relevant deadlines01/07/2022
Lead trustee identityMain contact for queries and noticesDOB, NI number, address
AssetsShows scope and possible liabilitiesProperty value, shares, cash totals

For practical step‑by‑step help on gathering information and completing the online form, see our guide to registering a trust in.

How to access TRS using a Government Gateway account

We guide you through the Government Gateway sign‑in so claiming and managing the online record is straightforward. This short section explains the account choice, security codes and how to avoid common lockouts.

A sleek, modern office workspace featuring a desktop computer displaying the HMRC Government Gateway portal on the screen. In the foreground, a focused professional in business attire is engaged in online navigation, with one hand on the mouse and the other resting on the keyboard. The middle ground includes a potted plant and a notepad filled with notes about tax registration, symbolizing organization and diligence. The background shows large windows with daylight streaming in, creating an uplifting atmosphere. The lighting is bright and inviting, emphasizing a sense of productivity and clarity. The image is captured from a slightly elevated angle to give a comprehensive view of the workspace, highlighting the interaction with the digital interface while maintaining a professional and clean aesthetic.

Creating Government Gateway sign‑in details and choosing an organisation account

To use the service you need a Government Gateway account. When you act for an arrangement you will usually choose an “Organisation” account, even for family matters. This keeps the arrangement’s access separate from personal accounts.

Set up with a clear email and a memorable password. Note your Gateway ID and keep it safe. Only the lead trustee should claim and manage the record, so agree who will do this before you begin.

Security codes and avoiding lockouts when details do not match

Security codes arrive by email, text or phone. Email codes can expire after 30 minutes, so complete the steps in one sitting where possible. If you enter mismatching personal details three times, you may be locked out for 30 minutes.

Practical tips to reduce problems:

  • Use the same device and browser for setup.
  • Check names, dates of birth and National Insurance numbers match your records.
  • Keep your Gateway ID and verification method secure and accessible.

If you need step‑by‑step official help, follow the guide to claim an account on the government site: claim a trustee account.

hmrc register trust tax step-by-step on the Trust Registration Service

This short guide takes you through the TRS flow in plain language, from choosing the type of arrangement to the final declaration.

Entering trust type and UK connections correctly

First, say whether the arrangement is an express arrangement set up by deed or will. The online form asks this early because it affects later questions.

If the arrangement is non‑UK, the service then asks about UK links. You must declare UK property purchases or any UK business relationship handled on behalf of the arrangement.

Adding beneficial owners and describing classes of beneficiaries

The next screens collect details of the settlor, trustees and beneficiaries. Add people as named individuals when possible.

For wider groups you can record a class of beneficiaries (for example, “all current and future grandchildren”). Keep this clear and simple.

Practical note: if more than 25 beneficiaries of one type exist, list 25 online and keep the rest in your own files for ease of management.

Submitting the declaration and what it means legally for trustees

The final step is a declaration. By signing, trustees confirm the information is complete and accurate.

Important: the declaration is a legal confirmation that you will keep details up to date and correct any changes within the required deadlines.

Save a copy of the confirmation. That proof helps when you act on behalf of banks or advisers and protects trustees if questions arise later.

After registration: URN vs UTR, proof of registration and what happens next

Once the online form is accepted, you will normally receive a short reference that confirms the arrangement is on the service.

When a URN or a UTR is issued

Plainly: if the arrangement becomes liable for tax, HMRC issues a UTR. If it is non-taxable and simply appears on the list, you get a unique reference number (URN).

Timescales and safe storage

References usually arrive within 15 working days. The lead trustee should note the reference and keep it safe.

Keep both a secure digital copy and a printed copy. Share a copy with your solicitor or adviser so someone can act on your behalf if papers are lost.

Downloading proof for banks and other relevant persons

You can download a PDF confirmation from the service. Banks, solicitors and other relevant persons use this when starting a business relationship.

ReferenceWhen issuedWhat to do
Unique Reference NumberNon-taxable listing (usually within 15 working days)Store securely; give PDF to bank or solicitor
Unique Taxpayer Reference (UTR)When liable for tax (sent within 15 working days)Use for Self Assessment; keep with other tax records
Proof PDFAvailable immediately after confirmationDownload, save encrypted copy, and share on behalf of the arrangement

Practical tip: record the reference in your trustee file and set a reminder to check details annually. This small step avoids delays when you need to prove the arrangement is trust registered.

Keeping the trust registered: updating details and ongoing trustee responsibilities

A small change can mean action within weeks, so regular checks pay off. We remind trustees that registration is not a one‑off task. Ongoing care keeps the arrangement accurate and defensible.

Updating the TRS register within 90 days of changes

Practical rule: trustees must update the service within 90 days of any change. Typical examples include the appointment of a new trustee, a beneficiary becoming known, an address update or a sale of property.

Annual declarations for taxable trusts and the 31 January deadline

If the arrangement is taxable, trustees must make an annual declaration by 31 January confirming details are current. Even if nothing has changed, that date matters for compliance and for any Self Assessment requirements.

Changes you must report

  • Settlor or trustee changes and contact details
  • New or known beneficiaries and their information
  • Material changes in assets, including property and significant shares
  • Any relevant controlling interest in offshore companies

Tip: hold a short annual review (even a phone call). Record the date, check values and update the form if required. For step‑by‑step help see our how to register a trust.

Penalties and compliance risks if you fail to register or keep details up to date

Small administration slip‑ups can carry big consequences. If you fail to keep the online record current, a trustee can face a penalty of up to £5,000. That fine is real and can erode the assets meant for beneficiaries.

When a £5,000 penalty can apply and what “deliberate” means

The £5,000 penalty applies where there is a failure to provide required information or to update the form within the deadlines. Authorities assess whether the failure was careless or deliberate.

Deliberate behaviour can include repeatedly ignoring reminders, withholding beneficial owner information, or failing to update after obvious changes. Each case is judged on its facts.

Practical steps to reduce risk

  • Keep clear records: deed, asset notes and a dated log of decisions.
  • Set reminders for 90‑day updates and the 31 January annual check.
  • Use a simple trustee file—digital and paper copies of confirmations and forms.
  • Seek professional guidance when property, cross‑border links or complex liabilities arise.

Our view: good record‑keeping and timely updates protect beneficiaries and reduce the chance of penalties.

Conclusion

In short, the practical steps you take now make ongoing compliance far easier.

Most family arrangements need a trust registration unless a Schedule 3A exclusion applies. The lead trustee must check this, act on deadlines and keep records up to date.

Our suggested order is simple: confirm the arrangement type and any exclusions, check which deadlines apply, gather documents, use the online service and keep your URN or UTR safe.

Keep details current within the required windows and complete annual checks where tax liability exists. If the arrangement involves UK property, overseas links or complex beneficiary groups, seek tailored advice.

With a short routine and clear files, staying on the register becomes manageable admin rather than a constant worry.

FAQ

What does the Trust Registration Service do and why does it exist?

The service collects details about trusts to meet anti-money laundering and tax transparency rules. It helps authorities know who controls assets and who benefits, so trustees can demonstrate compliance when dealing with banks, solicitors and other relevant persons.

Which roles within a trust does the service record?

The register records the settlor, trustees, beneficiaries and the lead trustee. It also asks for details of any protector, enforcer or person with significant control. These names and contact details show who makes decisions and who benefits.

Which trusts must be registered because they are liable for UK taxes?

Trusts that owe income tax, capital gains or inheritance charges in the UK must be entered on the register. That includes most discretionary and interest-in-possession arrangements where the trustees face a tax liability.

Are non-taxable express trusts ever required to be recorded?

Yes. Some express trusts that do not currently owe tax still need to be recorded because they hold UK property or have UK-connected trustees or beneficiaries. You should check the service guidance before assuming exemption.

Do non-UK express trusts with UK links need to be registered?

They can. If a trust created overseas owns UK land, operates a UK business or has UK resident trustees or beneficiaries, it may fall within the registration rules. Location of assets and people matters.

Which trusts are commonly excluded or fall under Schedule 3A exemptions?

Typical exclusions include will trusts that exist only for two years after probate, co-ownership trusts for property held jointly, and certain low-value or purpose-based trusts such as small pilot trusts and some child bank accounts. Pensions and many insurance arrangements are also often outside scope.

When does an excluded trust still need to be recorded?

An excluded trust must be entered if it needs a Unique Taxpayer Reference or if it becomes liable for a UK charge. If a tax return or tax payment is required, the exemption no longer applies.

What are the registration deadlines trustees must follow?

Deadlines depend on when the trust was created and whether it is taxable. Non-taxable trusts created on or before October 2020 had to be recorded by September 2022. Non-taxable trusts created after October 2020 generally must be added within 90 days. Taxable trusts have different deadlines for income and gains — trustees should check the specific rules for each tax type.

What basic information should I have before starting an application?

You will need the trust’s name and creation date, confirmation it is an express trust, lead trustee identity and contact details, settlor and beneficiary information, and an inventory of assets with approximate values for property, shares, cash and other holdings.

How do trustees access the register using a Government Gateway account?

Trustees use a Government Gateway sign-in. We recommend creating an organisation account if the trust is a shared responsibility. Keep sign-in details accurate and update contact information to avoid security code lockouts.

How should trustees enter trust type and UK connections on the form?

Choose the trust type that best matches the arrangement (for example discretionary or interest in possession) and accurately declare any UK connections such as property, trustees or beneficiaries resident in the UK. Incorrect choices can delay processing.

How do I add beneficiaries and describe classes of beneficiaries?

You should list named beneficiaries where applicable and describe classes (for example “children of X” or “grandchildren of Y”) when beneficiaries are not individually named. Provide as much identifying information as you can.

What does submitting the trustees’ declaration mean legally?

The declaration confirms that the information supplied is accurate to the best of the trustees’ knowledge. It carries legal responsibility and potential penalties if false or misleading information is provided deliberately.

When will a trust receive a unique reference number or a Unique Taxpayer Reference?

The register issues a Unique Reference Number once the entry is accepted. A Unique Taxpayer Reference is issued only where the trust needs one for tax purposes. Timescales vary but you should keep both references safe and accessible.

How soon can we expect evidence of registration and how should it be used?

Evidence is usually available to download soon after registration is complete. Trustees should store this for bank or solicitor requests and for future compliance checks.

How quickly must trustees update details when something changes?

Trustees must update the register within 90 days of a change to trustees, beneficiaries, settlors, assets or controlling interests. Prompt updates reduce the risk of penalties and keep records accurate for relevant persons.

Are annual declarations required for taxable trusts?

Yes. Taxable trusts typically require an annual declaration, often aligned with the 31 January deadline for certain tax returns. Trustees must check which deadlines apply to their trust type and taxes.

What changes are trustees required to report?

Report changes to trustees, beneficiaries, settlors, lead trustee details, trust name, trust assets and any person who has significant control. Even small changes can affect compliance, so record them promptly.

What penalties apply if trustees fail to register or update details?

Penalties can be applied, with fines up to £5,000 where failures are deliberate or careless. Persistent non-compliance attracts higher scrutiny. Keeping clear records and using reminders reduces risk.

What practical steps can trustees take to reduce compliance risk?

Keep an organised paper and electronic file of trust documents, set calendar reminders for updates and deadlines, and seek professional advice when in doubt. Good record-keeping is the simplest and most effective safeguard.

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