Trust Registration with HMRC: What Trustees Need to Know Part One

Setting up or managing a trust can be one of the most important financial responsibilities you’ll take on. While most people focus on the assets or beneficiaries, it’s just as important to understand whether the trust needs to be registered with HMRC—and how to do it correctly.

Getting it wrong can result in fines, interest, and extra administrative work, so it’s something all trustees should take seriously.

Who Needs to Register a Trust

Most UK trusts must be registered with HMRC on the Trust Registration Service (TRS). This includes:

• Trusts created during a person’s lifetime (inter vivos trusts)

• Trusts created under a will (testamentary trusts)

• Certain overseas trusts with UK tax liabilities

Some trusts are exempt, such as:

• Trusts with assets under £100 and no UK tax liability

• Charitable trusts already registered with the Charity Commission

If a trust falls outside these exemptions, it must be registered—failure to do so can lead to penalties.

What Information HMRC Requires

When registering a trust, trustees will need to provide:

• Details of the trust, including type and creation date

• Information on settlors, trustees, beneficiaries, and any controlling persons

• Details of the trust’s assets and liabilities

• Tax identifiers where applicable, including URN and UTR

Why URN and UTR Are Important

• URN (Unique Reference Number): HMRC creates the URN when the trust is first registered on the TRS. It acts as the trust’s “ID number” for all future correspondence, updates, and filings. Even if the trust currently has no UK tax liability, having the URN ensures any future changes or reporting are straightforward.

• UTR (Unique Taxpayer Reference): If the trust has a UK tax liability, HMRC issues a UTR. This is used when filing tax returns for the trust and ensures HMRC links the correct tax records to the trust.

Providing these numbers accurately when completing the TRS ensures:

• HMRC can correctly identify the trust

• Future reporting and payments are properly applied

• Trustees avoid delays or errors caused by missing or incorrect references

Deadlines for Registration

• Existing trusts with a UK tax liability should have been registered by 1 September 2022.

• New trusts must be registered within 90 days of creation.

Missing these deadlines can result in financial penalties and extra reporting obligations.

Multiple Trustees, Beneficiaries and Overseas Trusts

• Multiple trustees: All trustees are responsible for ensuring registration is completed.

• Overseas trusts: Non-UK trusts with UK tax liabilities also fall under the TRS rules and may need additional guidance on reporting and asset valuation.

Common Pitfalls to Avoid

• Confusing which trusts need to be registered

• Forgetting to include all relevant individuals (settlors, trustees, beneficiaries)

• Submitting incorrect information or failing to update HMRC when circumstances change

Keeping accurate records of all trust documents, correspondence, and valuations is vital.

Why Trustees Often Seek Professional Help

Trust registration can be complicated. Trustees often need support to:

• Ensure the right people are listed and the trust type is correctly identified

• Provide accurate asset valuations and tax references

• Avoid penalties for late or inaccurate registration

• Stay compliant with ongoing reporting requirements

Practical Tips for Trustees

• Register the trust as soon as possible after creation.

• Keep a digital record of all documents, including deeds, accounts, and correspondence.

• Update HMRC whenever there are changes to trustees, beneficiaries, or settlors.

• Record your URN once it’s issued—it’s needed for future updates or filings.

• Consider professional guidance—it can save time, reduce stress, and minimise the risk of fines.

Getting It Right

Registering a trust may feel daunting, but it’s essential for compliance and peace of mind. Professional advice ensures:

• The trust is correctly registered with HMRC

• All obligations are met on time

• Trustees can focus on managing the trust rather than worrying about penalties

Need Help With Trust Registration?

At Tax Matters, we help trustees, executors, and those establishing new trusts navigate the HMRC registration process. We’ll check which trusts must be registered, guide you through the TRS, and make sure everything is accurate and up to date.

Contact us today to make trust registration straightforward and stress-free.