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Non-UK trusts holding UK property face extended trust registration service requirements – In the news

New rules expanding the scope of the Trust Registration Service (TRS) came into force on 30 June 2026, bringing more non-UK trusts with UK property interests within HMRC’s registration regime.

The changes, introduced by the amended Money Laundering and Terrorist Financing Regulations, mean that non-UK trusts holding an interest in UK land or property acquired before 6 October 2020 may now need to register if they continue to hold that interest on or after 30 June 2026.

HMRC administers the TRS and requires many UK trusts, as well as certain overseas trusts with UK connections, to provide details of key parties including the settlor, trustees and beneficiaries.

Previously, non-UK express trusts with no UK trustees that held UK land or property acquired before 6 October 2020 were generally outside the TRS registration requirement unless they became taxable in the UK. The latest changes remove that historic distinction for affected trusts.

Trustees have been given a transitional period to comply. Any non-UK trust brought within scope by the new rules must be registered by 1 September 2027.

Trustees should review existing structures now to determine whether registration is required, gather the necessary information and consider whether ongoing record-keeping obligations may apply.

If you are unsure whether your trust is affected by the extended TRS rules, our Private Wealth team can provide clear advice on your obligations and support you with any registration requirements.

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This update is for general purposes and guidance only and does not constitute legal or professional advice. You should seek legal advice before relying on its content. Greenwoods Legal Services Limited is a Limited company, registered in England, registered number 16115882. Our registered office is Queens House, 55-56 Lincoln’s Inn Fields, London, WC2A 3LJ. Authorised and regulated by the Solicitors Regulation Authority, SRA number 8011813. Details of the Solicitors’ Codes of Conduct can be found at www.sra.org.uk. All instructions accepted by Greenwoods Legal Services Limited are subject to our current Terms of Business. VAT Reg No: 502 6933 06




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