Registration duties for non-UK trusts with UK property 7 July 2022

HMRC has revised its Trust Registration Service Manual to add detail on reporting a disposal of property by non-UK trusts and capital gains tax on UK property account.

UK and non-UK trusts are required to register on the trust registration service (TRS) if the trustees are liable to pay UK on UK assets or UK income of the trust.

The update clarifies that the requirement to register is not triggered by a UK tax liability arising to the trustees from non-UK assets. This includes situations where trustees are liable under IHTA 1984 Sch A1 to inheritance tax on shares in a non-UK company to the extent that the value of those shares is attributable to the value of UK residential property because the tax liability has arisen from non-UK assets.

If the ownership of any asset (or receipt of income from the asset) is treated as a...