The UK Government has brought in a significant expansion of registration requirements under the Trust Registration Service (TRS), expanding its ability to obtain information on certain non-UK trusts holding UK real estate, including the popular UK real estate holding vehicle of Jersey Property Unit Trusts (JPUTs).
What is the Trust Registration Service?
Introduced in 2017, the TRS was established to create a central register of the beneficial ownership of trusts. Designed to strengthen the UK’s anti-money laundering framework and reinforce confidence in the UK as a global investment destination, it requires trustees of relevant trusts to submit details to HMRC. Although information held on the TRS is not generally available to the public, certain details may be disclosed in limited circumstances to organisations and authorities engaged in combating financial crime, including money laundering and terrorist financing.
What is changing and why?
The scope of the TRS regime has evolved considerably since its inception. Initially, only trusts with specific UK tax liabilities were required to register. From 6 October 2020, the regime was broadened to include most UK trusts and certain non-UK trusts, irrespective of whether a tax liability arose. However, non-UK express trusts with no UK trustees that held UK land acquired before 6 October 2020 remained outside the registration requirement unless they became subject to UK taxation.
That exemption has now fallen away. From 30 June 2026, any non-UK trust that acquired an interest in UK property before 6 October 2020 and continues to hold that interest on or after 30 June 2026 must register for the TRS. Trustees have until 1 September 2027 to comply, with failure to register carrying the risk of a £5,000 penalty.
The changes are another step in the continuing drive towards greater transparency of ownership and enhanced anti-money laundering safeguards across the UK property market.
Why are JPUTs important for UK real estate?
For decades, JPUTs have been a cornerstone of UK real estate investment structures. Historically, they benefited from provisions that, in certain circumstances, enabled UK property to be transferred into a JPUT without incurring Stamp Duty Land Tax. While those advantages have long since disappeared, JPUTs continue to offer a range of attractive features, including the absence of stamp duty on transfers of their units, potential transparency for UK income tax purposes, and widespread recognition by lenders in the UK and internationally.
As a result, many JPUTs established before 6 October 2020 remain in place as holding vehicles for UK real estate. These structures will now be drawn into the TRS regime.
What now for trustees of non-UK trusts?
Trustees of non-UK trusts—not only JPUT trustees—should take the opportunity to review their arrangements and determine whether registration is now required. Key questions include whether the trust directly owns UK real estate, when was the property held by the trust acquired and was it still held on 30 June 2026.
