In the July article, we provided additional guidance on non-UK trusts which will be required to register on the Trust Registration Service (TRS) following the UK’s implementation of the Fifth Money Laundering Directive (5MLD).

However, at that point, the TRS was not ready to accept registrations of non-UK non-taxpaying trusts.

We are now pleased to confirm that from 1 September 2021 the TRS service became available for non-taxable trusts to register with HMRC. As the TRS was not updated in time to reflect the changes in the legislation, HMRC has pushed back the registration deadlines and are currently in the process of updating their guidance. In the meantime, the new registration deadlines released for non-taxable trusts are as following:

• Non-taxable trusts in existence on or after 6 October 2020 must be registered by 1 September 2022.
• Non-taxable trusts created after 1 September 2022 must be registered within 90 days.
• Changes to trust details and/or circumstances must be made within 90 days of the change.
  This effectively gives more time for trustees to assess the registration requirements of their trusts. It is also worth noting that the TRS registration guidance is currently being updated by HMRC. Thus, it is likely that there will be further developments.