Trust Registration Service and CGT on UK property.

Over the past few years, the Trust Registration Service has gradually become part of the normal administrative process for many trusts.

However, a recent update from HMRC means that trustees selling UK property may now need to think about registration slightly earlier than before.

What has changed

In February 2026, HMRC confirmed in their Agent Update that trusts which need to report Capital Gains Tax on UK property must first be registered on the Trust Registration Service before a CGT on UK property return can be submitted.

You can read the update here:
https://www.gov.uk/government/publications/agent-update-issue-140/issue-140-of-agent-update

In practical terms, this means a trust cannot simply file the CGT return following a property sale unless it has already been registered with HMRC.

Why this matters‍ ‍

Trustees disposing of UK property generally have only 60 days from completion to report and pay any Capital Gains Tax due.

If the trust has never previously been registered on the Trust Registration Service, the trustees may first need to complete the registration process before they are able to submit the CGT return.

This can create time pressure, particularly where the requirement is only identified after the disposal has taken place.

A common issue with older trusts

For many older trusts, this is quite a realistic situation.

Some trusts were created long before the Trust Registration Service existed, and trustees may only encounter the system when a tax event arises, such as the sale of a property.

Since the Trust Registration Service was introduced, several hundred thousand trusts have been registered as the rules have gradually expanded over time. However, many older trusts may still only encounter the system when a reporting obligation arises.

HMRC can impose penalties where a trust that should be registered is not registered, although in practice they will usually consider the circumstances and whether reasonable steps have been taken.

Further guidance on registering a trust can be found here:
https://www.gov.uk/guidance/register-your-clients-trust‍ ‍

When does this arise in practice‍ ‍

Situations where this often arises include:

• where a family trust owns a rental property that is being sold

• where trustees are disposing of a property that has been held for many years

• where executors are dealing with property held within a trust following a death

In cases like these, it is sensible to check whether the trust has already been registered before the disposal takes place.

Final thoughts‍ ‍

Where a trust holds property, it is becoming increasingly important to ensure that the administrative requirements are in place before a transaction occurs.

A short review of the trust’s position ahead of a sale can often avoid unnecessary pressure when the reporting deadline arrives.

If you are dealing with a trust property disposal, or are unsure whether a trust has been correctly registered, it can be helpful to review the position early.

We regularly assist trustees, executors and professional advisers with trust reporting and Capital Gains Tax matters, and we are always happy to have an informal conversation where it would be helpful to talk through a situation.