HMRC’s trust registration service: changes for employee trusts

Employee benefit trusts (EBTs) and employee ownership trusts (EOTs) with certain UK tax liabilities (i.e. taxable trusts) have been required to register with HMRC’s trust registration service (TRS) since June 2017 under the Fourth Money Laundering Directive (4MLD) (the Money Laundering Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations SI 2017/692). The TRS is the digital registration service for trusts which replaced the paper form 41G(Trust) notification process.

On 1 September 2021 HMRC confirmed that the TRS was able to accept the registration of non-taxable express UK trusts. This represents a significant extension to the TRS regime and means that all UK non-taxable trusts must now be registered. This was due to the changes introduced by the Fifth Money Laundering Directive (5MLD) which mean that subject...