TRSM32010 - Registration: contents: information required: contents: introduction
Source: gov.uk (2025-04-07)


TRSM20000 (https://www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual/trsm20000) sets out which trusts are required to register on the Trust Registration Service (TRS).

For all trusts required to register, the trustees need to provide certain information on the trust, as listed in the following pages. In addition to information on the trust itself, the trustees need to provide information on the persons involved in the trust.

The persons involved in a trust are the:

settlor

trustees

beneficiaries

any individual who has control over the trust, in some instances referred to as protectors (this is less common).

The settlor sets up the trust and provides property for the trust. The trustees hold the trust property in their name for the benefit of the beneficiaries. Sometimes, the trust deed provides for other persons to be associated with the trust, such as a protector who may be given the power to remove and appoint trustees.

These persons may be individuals or legal persons such as companies. Together, they are known as the “beneficial owners” of the trust.

All trusts registering on TRS must provide information on the trust and the beneficial owners of the trust, as listed in the following pages.

In addition, trustees of trusts which have a liability to UK taxation must provide extra information as specified at TRSM32080 (https://www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual/trsm32080).

Information missing at time of registration

Certain types of information are mandatory and their absence will be classed as a material discrepancy if missing.

Such information must be provided within the following timescales following the completion of the registration (when the service has produced the declaration).

Failure to provide mandatory information may result in a penalty of £5000 being issued to the trustee.

Taxable trusts created before 6 April 2021

Information must be completed following the end of the tax year in which the trust was registered.

All other trusts

Information must be completed within 90 days of the trust being registered.

Mandatory Information

The following information mandatory and must be provided at registration or subsequently updated by the deadlines set out above:

Lead trustees: name, country of residence, nationality, date of birth

For all individual, settlors, trustees and named beneficiaries: name, country of residence, nationality, date of birth

For all entities (trusts, charities, corporations etc): Name and address (including country)

Any information that is missing after those deadlines may be considered to be a material discrepancy (see TRSM70050).

Failure to provide mandatory information may result in a penalty of £5000 being issued to the trustee.

Mandatory information should not be deleted unless it is to amend an error.

Practicalities of gathering the required information

In certain situations (for example if a trust was settled many years ago) it may prove difficult for trustees to obtain all the required information for all beneficial owners at the point of registration on TRS. HMRC would expect trustees to undertake all reasonable efforts to obtain the required information. Trustees should register the trust on TRS with the information they have obtained and keep a record of the steps they had taken to attempt to obtain any missing information.

Trustees may be requested to provide the details of any missing information following a discrepancy report.

Requirement to provide information on previous beneficial owners

TRS is a register of beneficial ownership of trusts and as such should contain information on all beneficial owners of the trust since the time that the trust became liable for registration.

For registrable express trusts that were in existence on or after 6 October 2020 (see TRSM22010 (https://www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual/trsm22010)), this means that all individuals who have been beneficial owners for any period of time on or after 6 October 2020 should be recorded on TRS at the point of registration. Those individuals who have since ceased to be beneficial owners can be immediately removed from the record. This is to ensure that TRS contains a record of all beneficial owners from the point that the trust became liable for registration.