Trust Registration (TRS) & the 5AMLD

Introducing the TRS – Trusts & Trustee Registration Service

In June 2017 the Trust Registration Service (TRS) was introduced. The TRS is a online ‘one stop shop’ for trustees and personal representatives of complex estates to comply with their registration obligations. The TRS replaced the paper 41G registration form and informal process for trustees to notify HMRC of changes in their circumstances.

Trusts that are required to register with HMRC are required to do so through the TRS.

The TRS was originally only relevant where the trust had a UK tax liability or requirement to submit a tax return.

5AMLD – The Fifth Money Laundering Directive

There are several EU directives which the UK is implementing into its domestic legislation. The 5th Anti-Money Laundering directive (5AMLD) is one, which builds on the transparency push aimed at trusts.

The 5AMLD broadened the scope of the TRS by removing the need for a link to UK taxation. Amongst other things, it was suggested that UK express trusts and offshore trusts which hold UK property or enter a business relationship in the UK will have to register with the TRS even if there were no UK trustees.


HMRC opened a consultation on the new TRS and the results have recently been published.

Several helpful changes were made based on recommendations made by 124 stakeholders, the key one being the requirement for offshore trustees.

Offshore trustees entering into a business relationship in the UK will not have to register on TRS unless there is at least one UK-resident trustee. However, any non-UK trust that acquires UK land or property will be required to register.

The response included the final categories of trusts which are not required to register which helpfully provided an exemption for trusts such as:

  • Charitable trusts registered in the UK
  • UK registered pension trusts
  • Will trusts created on death (some will trusts may be required to register but the majority should be exempt)
  • Trusts for vulnerable beneficiaries or bereaved minors

How to register a trust on the TRS 

Trustees who are required to register must do so online at https://www.tax.service.gov.uk/gg/sign-in?continue=/trusts-forms/form/registration-of-a-trust/new.

Before you can register, you must apply online for an Government Gateway account to obtain a Unique Taxpayer Reference (UTR). A separate account is required for each trust even if the settlor and trustees are the same.


There is registration deadline of 10 March 2022 for existing trusts to register, or update their records if they have already registered on TRS. There is a 30 day deadline for new trust registrations and updates.

We have a team of experts who are on hand to assist with any of your reporting obligations under the TRS – please do get in touch with any queries.

ETC Tax & Trusts

For more info on setting up a trust of for help and advice check out the articles about trusts and trustees!

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