Fines for not registering a trust on the trust registration service

Since legislation introduced on 6 October 2020 all express trusts – other than excluded trusts – have to be registered on the trust registration service (TRS) by the later of 1 September 2022 or 90 days from the date the trust was created. Details of the trusts that are required to register on the TRS are set out in HMRC’s Trust Registration Service Manual at para TRSM21010.

To date very little has been said about the penalties that will apply for non-compliance. HMRC updated the manual on 2 August 2022 and added a new section TRSM80000 dealing with the penalties that HMRC may levy against trustees (see tinyurl.com/hmrctrsm80000).

The text below is reproduced from TRSM80020:

‘In recognition of the fact that the registration requirement is a new and unfamiliar obligation for many trustees there will be no penalty for a...