Further TRS updates on data requests and reporting discrepancies
In this month's Digital Services Update, HMRC has shared some further information on the Trust Registration Service.
Each month, HMRC provide an update on any changes to their digital services. We have reproduced below the text in the update which relates to the Trust Registration Service.
Trust Registration Service
Deadlines for registering a trust with HMRC
The deadline for registering most trusts on the Trust Registration Service (TRS) is 1st September 2022. More information on the trusts that need to register and the trusts that are excluded can be found at Trusts and Estates: detailed information. Further detailed technical information can also be found in the Trust Registration Service Manual.
Reporting a discrepancy in Trust Registration Service data.
From 1 September 2022, a Relevant Person is required to report a discrepancy in Trust Registration Service data to HMRC. A Relevant Person is an organisation working in a professional capacity that carries out due diligence checks under anti-money laundering regulations.
Discrepancy Reporting guidance has been published in TRSM70000. GOV.UK guidance will be available by 1 September 2022.
Trust Data Requests
From 1 September 2022, Trust Data Requests can be submitted to HMRC. HMRC may share information on the Trust Registration Service (TRS) in limited circumstances with some third parties following a Trust Data Request.
Trust Data Request guidance has been published in TRSM60010. GOV.UK guidance will be available by 1 September 2022.
How to report that beneficial owners of a trust may be at disproportionate risk of harm if their data is shared
HMRC will not share information on specific individuals if the release of that information would put beneficial owners at a risk of harm.
If you consider that any beneficial owner of the trust would be exposed to a disproportionate risk of fraud, kidnapping, blackmail, extortion, violence or intimidation as a result of their trust information (full name, month and year of birth, nationality, country of residence and their beneficial interest in the trust) being disclosed, please let HMRC know.
Trustees should send an e-mail, putting ‘Beneficial owners at risk of harm’ in the subject line to:
Only information reporting a Risk of Harm is accepted to this mailbox which is sent at owner’s risk and HMRC will not be liable for any interception of that information.
Technical guidance can be found at TRSM60040.
GOV.UK guidance is now available Register a trust as an agent - GOV.UK (www.gov.uk) under the How to Register section.
HMRC will only assess the information you provide to determine whether the exemption applies if a Trust Data Request about your trust is received. Sending an email does not guarantee that HMRC will agree that the exemption applies.
If you have any comments or queries on the above, please let us know at [email protected]. Please note that due to the volume of TRS queries we may not be able to respond individually, but all feedback will be noted.