Recent changes to the UK's Trust Registration Service (TRS) have significantly expanded the range of non-UK trusts required to register, creating new compliance obligations for some offshore structures that have historically fallen outside the registration regime.
What has changed?
From 30 June 2026, amendments to the Money Laundering Regulations have extended the TRS registration requirements to certain non-UK express trusts holding UK real estate.
Previously, non-UK trusts were generally only required to register where they acquired a UK land interest on or after 6 October 2020.
Under the new rules, registration may now be required where a non-UK trust:
- acquired a UK land interest before 6 October 2020; and
- continued to hold that interest on 30 June 2026.
This change substantially broadens the scope of the regime and brings many long-standing offshore property structures into consideration for the first time.
Who could be affected?
A range of offshore property holding arrangements may now require review, including certain:
- Jersey Property Unit Trusts (JPUTs)
- Guernsey Property Unit Trusts (GPUTs)
- offshore family trusts
- investment and property holding trusts
- other non-UK express trusts holding UK real estate
Whilst some exemptions remain available, trustees and advisers should not assume that existing structures are outside the scope of the new rules.
What action should be taken?
We recommend reviewing any non-UK trust that directly holds UK real estate to determine:
- whether the new registration requirements apply;
- whether any exemption may be available; and
- what information will be required for registration.
Although the deadline for newly affected trusts to register is 1 September 2027, the work involved in reviewing structures and gathering the necessary information can be significant.
HMRC has also confirmed that the registration process for these newly in-scope trusts is not yet available online, with further guidance expected in due course.
How we can help
Trowers & Hamlins advises trustees, fiduciaries, family offices, intermediaries and property investors on trust, tax and regulatory compliance matters.
If you would like to discuss whether these changes may affect your clients or existing structures, or would like assistance preparing for future TRS registrations, please get in touch.
