Trust Registration Service Update

Further to our news item on 1 September 2021 highlighting that the Trust Registration Service has now opened for the registration of non-taxable trusts, we are pleased to provide some further updates today from HMRC. 

We reported on 1 September that the TRS was now open for the registration of non-taxable trusts, following the extension of registration requirements to non-taxable trusts (unless specifically excluded) on 6 October 2020. 

HMRC have confirmed to us that the deadline for upgrading the details of taxable trusts will also be 1 September 2022. Similarly, this will be the date at which the register will open for legitimate interest requests and third country entity requests.

We also reported previously that, from 1 September 2022, newly created trusts will need to register within 90 days of creation (unless they fall within one of the exceptions) with trusts created prior to that date having to register by 1 September 2022. HMRC have helpfully confirmed that any trust created within 90 days of the 1 September 2022 deadline will have 90 days to register, as otherwise a trust created on 15 August 2022 say, would have very little time to register if it had to hit the 1 September 2022 deadline. Effectively new non-taxable trusts will have the later of 90 days from creation or 1 September 2022 to register.

HMRC have also confirmed that the Government is intending to make some welcome changes to the list of excluded trusts which will not be required to register on the TRS unless they acquire a UK tax liability.  HMRC have confirmed that we can share the following details: 

"Trusts holding healthcare insurance policies

We would also like to confirm that in line with the policy intention, amendments will be made to the legislation to clarify that all healthcare policies held in trust, including those that are not part of a wider life policy, are excluded from registration.

Child bank accounts

Amendments will be made to the legislation to ensure that trusts required in order to open a bank account for a child are excluded from registration."

We are aware from member feedback that the changes to child bank accounts will be very welcome. 

We are continuing to work with HMRC on various matters in connection with the TRS including guidance and practical issues with the TRS. atttechnical [at] (subject: TRS%20comments%20and%20concerns%20) (Comments and concerns from members) continue to be very welcome. 


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