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Trust registration – important update for trustees

HMRC have recently made changes to the Trust Registration Service (TRS) which mean that many trusts which were previously exempt from registration will need to be registered by 1 September 2022.

If we already act on behalf of a trust with which you are associated then we will be in touch directly to ensure that the trust is registered if this was not previously required, and that any entries in the trust register are up-to-date. Please note that where a trust has been registered, there is an ongoing requirement to update the TRS within 90 days of any changes.

The requirement to register now includes trust arrangements which typically have had no tax liability or reporting requirements in the past, such as ‘bare trusts’ (where property is held as nominee) and those with no income or gains, although some of these are still excluded from requirements. We therefore recommend that if you are unsure then please do contact us for advice or review the registration requirements at

If you are a trustee and believe that there is a requirement to register a trust, details of how to begin this process can be found at the link above. If you have queries regarding the requirement or would like us to register a trust on your behalf please contact us on .

Where deadlines are not met, HMRC can issue penalties to trustees; however they do recognise that the registration requirement is a new and unfamiliar obligation for many trustees and have indicated that there will be no penalty for registering late unless it is shown to be due to deliberate behaviour.

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