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Trustees: yet more compliance looms

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By Sue Crosby

The UK Trust Registration Service is gradually being developed and requires more information. As a Trustee of a tax paying trust, you may have already had to engage with the Online Register, but this is now being extended to the vast majority of UK express trusts.

With effect from June 2017, trustees have been required to submit and maintain information for the trust on all interested parties and the assets held in trusts that are registrable. Up to this point registerable meant a trust that had a tax liability. Now all express trusts have to be registered even if there is no liability.

The purpose of the register is to assist HMRC to collect and maintain information on the beneficial ownership and assets held in registerable trusts assisting in combating money accordance with the 5th Money Laundering Directive.

A trust is not a public record and no documents are submitted onto the Trust Register. It is impossible to retrieve a trust document from a public office, agency or anyone who is not a beneficiary and does not have the rights to know about the details your trust.

The current reporting deadlines for trusts set up before 6 April 2021 mean they should be registered by 31 January 2022. In future, taxable trusts set up before 9 February 2022 should report by 10th March 2022. There will temporarily be two reporting deadlines in operation.

From 9 February 2022, trustees will have 30 days to register from the triggering event. This could be the assets transferring into the trust, incurring the first tax liability, acquiring land. The big change is that the register has to be updated within 30 days of the trustee becoming aware of any changes. If the trustee does not register, the Revenue will write a nudge letter, but if you fail to report after a second reminder, they could impose a penalty of £100.

For trusts already on the register before May 2021, the trustee may have a requirement to update any report already made.

Information on all interested parties needs to be kept up to date and any changes must be completed within 30 days especially for the first-named trustee's name and address. The changes you can make include adding, amending or deleting details.

The Trust Register is a separate online access to Self Assessment. However, within the Trust and Estate Tax Return submission the trustees have to confirm that the Trust Register is up to date each year, even if no changes have been required. If the trust is not liable to tax, you do not have to report any changes until the trust becomes liable to tax. At the end of the trust, even if you have updated the Register, it may still be necessary to file a Self Assessment Tax Return.

As a trustee, in addition to dealing with the management of the trust, you now have to control sensitive personal information for all the associated parties being in order, to maintain the access to the Trust Register and Self Assessment.

If you would like any assistance with the impact of the new changes, please contact our Trusts team.

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