The Trust Registration Service (TRS) Challenges One Year On

Whilst we have become increasingly accustomed to the requirements of the TRS since its full introduction on 1 September 2022, there remain some ongoing challenges around what needs to be input on the register.

This has been particularly true if trustees are entering the details for discretionary trusts. Each relevant class of beneficiary detailed in the trust deed must be included in the beneficiary details section. In the case of our specimen discretionary trust deed these classes would be shown as follows:

Any beneficiaries stated in the deed should also be registered as individual beneficiaries. For example, where an intended beneficiary is included in the ‘additional beneficiaries’ section of the trust deed they should also be included as an individual beneficiary on the TRS. Once benefits are distributed from the trust, the recipient beneficiary will also then need to be registered as an individual beneficiary.

When adding a beneficiary on the TRS the first thing to do is select the type of beneficiary. Where the beneficiary is an individual the details to be added will include name, date of birth, nationality, country of residence and confirmation of mental capacity status.

Where a class of beneficiary is to be added then either the full class definition from the trust deed can be included or an accurate description of the class can be provided. As the field is limited to 56 characters, if the verbatim class definition is to be used it may have to be spread across two input fields.

The correct registration of trusts on the TRS, and the requirement to provide evidence of such, is now an embedded part of the establishment of new relationships between trustees and ‘relevant persons’ such as advisers and providers. Moreover, since 1 April 2023 it is now also important as part of the ongoing relationship as evidence of any changes to the registration details, which must be entered on the register within 90 days of a change, are required before withdrawals can be made from the trust.

The above is based on our understanding of the guidance set out in the Trust Registration Service Manual published by HMRC which can be found here: www.gov.uk/hmrc-internal-manuals/trust-registration-service-manual.

1. Introduction
2. Transact Online (TOL) – Recent Enhancements
3. Electronic Fee Reconciliation Data
4. COPS Update
5. Clients Can Add Their Nominated Bank Account Details via TOL
6. Share Class Conversion
7. Transact- BlackRock MPS Events
8. The Trust Registration Service (TRS) Challenges One Year On
9. Fund Changes
10. Interest on Cash Deposits
11. Transact Events 2023