UK Trust Tax Compliance and Reporting in 2025: TRS, SA900, and Offshore Obligations

The Trust Registration Service

The Trust Registration Service (TRS) is HMRC's central register of UK trusts and offshore trusts with UK connections. It was established initially under the UK's implementation of the EU's Fourth Anti-Money Laundering Directive (4AMLD) and was significantly expanded from September 2022 by the Fifth Anti-Money Laundering Directive (5AMLD) transposition.

Which Trusts Must Register

As of 2025, the following trusts must be registered on the TRS:

UK express trusts (including UK resident non-taxable trusts):

• All UK express trusts — trusts expressly created by a settlor, as distinct from trusts arising by operation of law (resulting and constructive trusts)
• Even non-taxable trusts must now register (the previous limit to taxable trusts was removed by the 5AMLD expansion)

Non-UK trusts with UK connections:

• Trusts that acquire UK land or property
• Trusts with UK tax consequences (any UK tax liability arising)
• Trusts where the trustee is a UK-resident business

Excluded Trusts

The following trusts are excluded from TRS registration:

• UK registered pension scheme trusts (regulated by The Pensions Regulator)
• Charitable trusts registered with the Charity Commission
• Co-ownership trusts (bare trusts for joint property ownership)
• Life insurance trusts (holding a life insurance policy that only pays out on death or terminal illness)
• Bereaved minor trusts and immediate post-death interests arising from a will (for the first two years)
• Financial service regulatory bare trusts

Registration Deadlines and Process

New trusts must be registered within 90 days of creation. The registration is made through HMRC's TRS online portal. Trustees must provide:

• Trust name and date of establishment
• Settlor details (name, date of birth, NI number or UTR)
• Trustee details
• Beneficiary details (named beneficiaries and classes of potential beneficiary)
• Trust asset details (nature and approximate value)

Failure to register a registrable trust by the deadline incurs a penalty of £100 per month of delay, up to a maximum of £900.

The SA900: Trust and Estate Tax Return

UK resident trusts with UK tax obligations must file an SA900 Trust and Estate tax return annually. The SA900 is due by 31 January (online filing) or 31 October (paper filing) following the end of the tax year in which trust income or gains arose.

When an SA900 Is Required

An SA900 must be filed where:

• The trust has income or gains in the tax year
• The trust has made a distribution to a beneficiary
• HMRC has issued a notice to file

A trust with no income and no distributions is not required to file an SA900 — but the trustees must still maintain records that demonstrate this, in case HMRC queries the position.

What the SA900 Reports

The SA900 reports:

• Total income from all sources (interest, dividends, property income, trust trading income)
• Deductible expenses and trustee management costs
• Income allocated to beneficiaries (with certificates of deduction of tax — Form R185)
• Capital gains (on a separate capital gains supplementary page)
• Trust tax rates applicable (accumulation trusts pay the "trust rate" of 45% on non-dividend income above the £1,000 rate band; dividend income in trust is taxed at 39.35% above the £1,000 trust rate band)

The £1,000 standard rate band for trusts (reduced from its previous level) means that the first £1,000 of trust income is taxed at the basic rate (20% on non-dividend income, 8.75% on dividends). Income above £1,000 within an accumulation or discretionary trust is subject to the trust rates.

Income Type	Below £1,000 Band	Above £1,000 Band (Accumulation/Discretionary)
Non-dividend income	20%	45%
Dividend income	8.75%	39.35%
Capital gains	Standard CGT rates	Standard CGT rates

Offshore Trust Reporting: Form 50FS and DOTAS

Form 50FS: Offshore Trusts with UK-Resident Trustees or Settlors

Where an offshore trust has UK-connected parties (UK resident trustees, UK resident settlor, or UK resident beneficiaries who have received benefits), specific notification and reporting obligations apply under Schedule 36 Finance Act 2008.

The primary offshore trust reporting obligation for UK-resident settlors is the annual "offshore income gains" disclosure on the self-assessment return — but this applies to actual income attributed to the settlor (under the settlement provisions), not to the trust's offshore accumulation.

For offshore trusts that distribute capital to UK-resident beneficiaries, the trustees must provide the beneficiary with details of the distribution sufficient for the beneficiary to determine whether it matches a capital gain for section 87 TCGA 1992 purposes. There is no standard form for this — it is typically provided via a trustee letter or distribution statement.

DOTAS: Disclosure of Tax Avoidance Schemes

The Disclosure of Tax Avoidance Schemes (DOTAS) regime (Finance Act 2004, Part 7) requires promoters of tax avoidance schemes to notify HMRC of those schemes. Trustees implementing arrangements that fall within the DOTAS hallmarks (broadly similar to the DAC6 hallmarks for UK-domestic arrangements) must ensure that the required disclosures have been made.

Schedule 36 Information Powers

HMRC has broad information-gathering powers under Schedule 36 FA 2008 to issue information notices to taxpayers and third parties (including offshore trustees) seeking documents and information relevant to a tax position. An information notice can require production of:

• Trust deeds
• Trustee minutes and board resolutions
• Financial statements
• Correspondence regarding trust administration
• Asset valuations

Failure to comply with a Schedule 36 information notice incurs a £300 initial penalty and £60 per day thereafter. In cases of suspected deliberate concealment, the penalties can be significantly higher.

The Trust Rate Band: Practical Management

The £1,000 standard rate band for discretionary and accumulation trusts is shared across all trusts settled by the same settlor (pro-rated among them). A settlor who has established three discretionary trusts splits the £1,000 rate band equally — each trust has a £333 standard rate band before the 45% trust rate applies.

Trustees of accumulation trusts who accumulate significant income (bank interest, property rental, UK dividends) above the £1,000 band face trust-rate taxation at 45%. Where beneficiaries have lower personal income tax rates than 45%, distributing income to beneficiaries — who can then claim a refund of the excess tax credit — is more efficient than accumulating.

The Form R185 (Certificate of Deduction of Tax) must be provided to each beneficiary who receives income from the trust, showing the gross income amount and the tax deducted at the trust rate. The beneficiary includes the gross amount in their own return and claims credit for the tax paid by the trustee.

HPT Group manages annual trust tax compliance for trustees of both UK and offshore trusts with UK connections, including SA900 filing, TRS registration management, beneficiary reporting, and the provision of specialist advice on offshore trust attribution and reporting obligations under the post-April 2025 regime. Trust compliance has become more complex and more closely scrutinised by HMRC in recent years — professional trustee administration is no longer an optional luxury. Contact our trust administration team or apply for a compliance review.