October 28, 2021


The 5th Anti Money Laundering Directive stipulates that all trusts (whether or not they produce any taxable income) in existence on or after 6 October 2020 must be reported to HMRC via the Trust Registration Service (TRS) by 1 September 2022. Trusts created after 1 September 2022 originally had a 30-day deadline to register. However, HMRC have announced that this deadline will be extended to 90 days. This 90-day deadline will also apply to updating trust information already on the register as at 1 September 2022. Amendments will be made to the existing legislation shortly.

Back in March 2021, HMRC announced that the TRS would not be ready to accept trust registrations by that point; it has only been in a position to do so since the end of August 2021. This delay had caused some concern that the original registration deadline of 10 March 2022 would not be met, so that deadline was extended to the September 2022.

Concern still exists about the scope of the 5th directive, whose definition of those trusts required to be registered includes bare trusts – something which HMRC doesn’t recognise as a trust, and which most people wouldn’t regard as a trust either. Concern about access to the register and the general lack of awareness of the new obligation still exists amongst the legal and accountancy professionals. This extra time to register new trusts will therefore no doubt be well received.


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