National statistics

Statistics on trusts in the UK October 2023

Updated 12 October 2023

Summary of key statistics

The latest statistics show that:

  • the Trust Registration Service (TRS) had 633,000 trusts and estates registered up to 31 March 2023 and that remain open as at 31 August 2023

  • around three-quarters of registered and open trusts and estates were registered in the period between 1 April 2022 and 31 March 2023, when there were 462,000 new registrations

  • the total number of trusts and estates that have made Self Assessment returns has continued to decline, reducing by 3% in the tax year ending 2022 in comparison to the previous year

  • total income of trusts and estates in tax year ending 2022 was £3,075 million, moving above pre-pandemic highs where income was £3,050 million in the tax year ending 2020

  • Capital Gains Tax payable increased by 27% in the tax year ending 2022 when compared to the previous year, reaching £1,055 million

An ‘interest in possession’ trust is one where the beneficiary is entitled to trust income as it arises. A discretionary trust is one where trustees have ‘discretion’ about how to use the income of the trust, and sometimes the capital. Discretionary trusts pay tax at the special trust rates. For the purposes of this publication, ‘other trusts’ include estates and all other types of trusts that are not interest in possession trusts or trusts paying tax at the special trust rate, such as heritage maintenance trusts, vulnerable beneficiary trusts and charities. Further information is provided in the background quality report accompanying this publication, or at Trusts and taxes.

TRS is primarily designed as an administrative system which is a part of the United Kingdom’s anti-money laundering legislation. We have undertaken an analytical data cleaning process to ensure that we have data that is sufficiently fit-for-purpose for publication of some simple aggregations of data to provide summary information on the numbers of trusts and estates. These figures are provided in figure 1 and table 1 and are based on a data extract taken from TRS on 31 August 2023. Within this cleaning we aim that each trust or estate is only counted once, and the most recent data relating to that trust or estate indicates that they remain open. Further details of the cleaning process can be found in section 3.4 ‘Data validation’ in the background quality report accompanying this release. We believe that taking these steps and mitigations mean that these aggregated figures meet the quality standards required to be badged as National Statistics.

Following on from a recent statistics consultation we have made some amendments to this publication. We have combined the number and income tables for each of trusts taxed at the special trust rates and interest in possession trusts. As a result, tables 3 and 5 have been combined into a single table which is now table 3, while tables 6 and 8 have been combined into table 5. We have shortened the time series in all tables to include the latest 11 tax years where applicable, including figures 3, 6 and 9 in the main commentary. The historic data and tables remain available from The National Archives website.

Changes in trust income and taxation for the tax years ending 2021 and 2022 may have been affected by the economic impacts of the COVID-19 pandemic, therefore different factors may have affected these tax years compared to previous years.

Trust registrations

Figure 1: The number of non-taxable trusts registered as open on TRS rises substantially in period between 1 April 2022 to 31 March 2023

We have changed the way we are counting registered trusts and estates since the previous publication and now exclude from these figures records that have subsequently been marked as closed or obsolete. These figures now represent the number of new trust and estate registrations in each 12-month period ending March, that are still recorded as open as of 31 August 2023. Some figures up to and including the 12-month period ending March 2022 have decreased as a result. In general, trust and estate registration figures for earlier years are expected to decrease slightly with time as trusts and estates close.

Figure 1 shows that in the 12-month period up to 31 March 2023, 462,000 trusts and estates registered on TRS and remain open as of 31 August 2023, which is a substantial increase from the previous 12-month period when there were 33,000 registrations. Around 90% of the trusts and estates registered in the 12-month period up to 31 March 2023 are non-taxable trusts. This is mainly due to the high volume of registrations leading up to the 1 September 2022 deadline for the registration of all UK express and non-express trusts even if they have no tax liability, unless they are exempt (see section 3.1 ‘Source data’ of background quality report). The number of estate registrations has continued to increase at a similar rate to previous years, with around 6,000 estates registered and recorded as open in the period between 1 April 2022 to 31 March 2023.

The total number of trusts and estates registered and recorded as open on TRS has continued to increase since its inception in mid-2017, with 633,000 trusts and estates registered and open until 31 March 2023. These figures may change over time as the data within the service is updated (for example due to trust closures) and improved.

Table: Number of additional trusts and estates registered and recorded as open on Trust Registration Service in each year

12-month period ending 31 March Total no. of trusts (taxable and non-taxable) No. of non-taxable trusts No. of estates
2018 82,000 NA 5,000
2019 17,000 NA 5,000
2020 10,000 NA 4,000
2021 10,000 NA 4,000
2022 28,000 16,000 5,000
2023 455,000 415,000 6,000

Figure 2: The number of trusts and estates submitting Self Assessment continues to fall

Figure 2 shows that the total number of trusts and estates in the UK submitting Self Assessment returns fell by 3% in the tax year ending 2022 compared to the previous year (see supplementary table 2). This decline continues the long-term downward trend across all the main types of trust, with the total number of trusts and estates submitting Self Assessment returns reducing by 12% since the tax year ending 2017. There were 161,000 trusts and estates submitting Self Assessment returns in the tax year ending 2017, which has fallen to 141,500 in the tax year ending 2022. The figure provided for the tax year ending 2021 in the previous release (October 2022) has been revised upwards from 141,500 to 146,000 in this release (see section ‘Revisions strategy’).

Table: Numbers per tax year broken down by type

Tax year ending Total Trusts paying tax at the special trust rate Interest in possession trusts Other trusts
2004 225,000 112,000 100,500 12,500
2005 220,500 116,500 93,500 11,000
2006 210,000 110,000 90,000 9,500
2007 203,500 118,500 74,500 11,000
2008 201,000 114,000 76,500 10,500
2009 195,500 110,000 75,000 10,500
2010 182,000 104,000 68,000 10,000
2011 168,000 96,000 61,500 10,500
2012 166,500 95,500 59,500 12,000
2013 164,500 93,500 56,500 14,500
2014 171,500 95,500 59,000 17,000
2015 167,000 94,000 56,500 17,000
2016 165,000 93,500 55,000 16,500
2017 161,000 91,000 52,500 17,000
2018 156,000 89,500 50,500 16,500
2019 157,000 90,500 50,500 16,000
2020 152,000 87,500 49,000 15,500
2021 146,000 84,500 45,500 16,500
2022 141,500 82,000 44,000 15,500

Interest in possession trusts

Figure 3: The number of interest in possession trusts continues to fall

Figure 3 shows the number of interest in possession trusts submitting Self Assessment returns in each income band, (see supplementary table 3). There has been a 3% fall in the number of interest in possession trusts between the tax years ending 2021 and 2022. This decrease in the number of interest in possession trusts is mainly driven by trusts with income between £1,000 and £10,000.

Figure 4: Income of interest in possession trusts varies yearly but only with small changes

Figure 4 shows the level of income and gains for interest in possession trusts by income type (see supplementary table 4). Total income was £1,085 million in the tax year ending 2022, which represents a 16% increase when compared to the previous year. There has been an increase across all income types except for interest income, with dividend income rising by around one-fifth to £520 million. Chargeable gains for interest in possession trusts is £1,780 million in the tax year ending 2022, which is a recent high.

Table: A breakdown by income type and gains for interest in possession trusts

Tax year ending Dividend income (£ million) Interest income (£ million) Property income (£ million) Other income (£ million) Total income (£ million) Chargeable gains (£ million)
2018 535 60 335 175 1,105 1,475
2019 620 70 390 210 1,295 1,470
2020 580 65 330 160 1,135 1,545
2021 440 50 315 135 935 1,730
2022 520 45 330 190 1,085 1,780

Figure 5: In the tax year ending 2022, 7% of interest in possession trusts had 71% of the income

Figure 5 shows the distribution of these trusts by band of income (see supplementary table 3). There were 44,000 interest in possession trusts in the tax year ending 2022. Around 46% of interest in possession trusts had income of less than £1,000, with their total income being less than £5 million. Around 7% of trusts had income of more than £100,000, accounting for £765 million of income. Overall, approximately one-fifth of interest in possession trusts had income greater than £20,000 and these trusts accounted for around 91% of the total income. The income distribution for interest in possession trusts is more skewed towards the highest income band (£100,000 or more) in the tax year ending 2022 when compared to the previous year. Income in this band has increased substantially by 24%, while income in all other bands has remained at similar levels. Trusts in the highest income band now account for 71% of all income, compared to 66% in the tax year ending 2021.

Table: Income bands for interest in possession trusts in tax year ending 2022

Income band (£) Total Number Income (£ millions)
less than 0 <500 <5
up to 1,000 20,500 <5
1,000 to 5,000 6,500 20
5,000 to 10,000 4,000 30
10,000 to 20,000 4,000 55
20,000 to 50,000 4,000 110
50,000 to 100,000 2,000 110
100,000 or more 3,000 765

Trusts paying tax at the special trust rate

The statistics shown below for trusts paying tax at the special trust rate cover both discretionary and accumulation trusts.

Figure 6: The number of trusts taxed at the special trust rates falls

Figure 6 shows the number of trusts paying Income Tax at the special trust rates by income band (see supplementary table 5). The number of trusts paying tax at the special trust rates in the tax year ending 2022 has decreased by 3% when compared to the previous year. The number of these trusts has fallen in every income band between £0 and £10,000, which accounts for just under three-quarters of these trusts. Trusts with income between £5,000 to £10,000 decreased most (by 8%).

Figure 7: Dividend income among trusts paying Income Tax at the special trust rates returns to pre-pandemic levels, while chargeable gains rise substantially

Figure 7 shows the income and gains breakdown for trusts paying tax at the special trust rate (see supplementary table 6). The total income of trusts paying tax at the special trust rates was £1,615 million in the tax year ending 2022, rising by 18% compared with the tax year ending 2021. This increase is mainly driven by a 37% rise in dividend-type income to £940 million, which is now closer to pre-pandemic levels of £965 million observed in the tax year ending 2020.

Chargeable gains for trusts paying tax at the special trust rates has increased substantially to £2,805 million in the tax year ending 2022, compared to £1,920 million in the tax year ending 2021. Historic data shows that chargeable gains can be volatile on an annual basis and it is unclear whether the increase in the tax year ending 2022 is part of a longer-term trend.

Table: A breakdown by income type and gains for trusts paying tax at the special trust rate

Tax year ending Dividend income (£ million) Interest income (£ million) Property income (£ million) Other income (£ million) Total income (£ million) Chargeable gains (£ million)
2018 770 105 320 225 1,415 1,460
2019 795 115 325 240 1,480 1,885
2020 965 100 320 240 1,630 1,300
2021 690 80 320 280 1,370 1,920
2022 940 80 330 265 1,615 2,805

Figure 8: In the tax year ending 2022, 4% of trusts paying tax at the special trust rate had 67% of the income

Figure 8 shows the number and income of trusts paying tax at the special trust rates (see supplementary table 5). There were around 82,000 trusts paying Income Tax at the special trust rates in the tax year ending 2022. Of these, 32,000 had income less than £1,000, while 3,500 trusts had income greater than £100,000.

The income of trusts paying tax at the special trust rate with income more than £100,000 increased from £845 million in the tax year ending 2021 to £1,085 million in the tax year ending 2022. The trusts in this income band accounted for around 67% of the total income in the tax year ending 2022, compared to 62% in the previous year.

Table: Income bands for trusts paying tax at the special trust rate for tax year ending 2022

Income band (£) Total Number Income (£ millions)
less than 0 <500 <5
up to 1,000 31,500 5
1,000 to 5,000 17,000 55
5,000 to 10,000 10,500 85
10,000 to 20,000 9,000 110
20,000 to 50,000 7,000 160
50,000 to 100,000 3,000 135
100,000 or more 3,500 1,085

Tax Liability

Figure 9: Income Tax liability and Capital Gains Tax payable on chargeable gains of trusts and estates increases in the tax year ending 2022

Figure 9 shows tax payable on income of trusts, split between different types of trust. Total Income Tax increased to £765 million in the tax year ending 2022, an increase of 13% compared with the previous year (see supplementary table 8). Over three-quarters of Income Tax comes from trusts paying tax at the special trust rate, which increased by 14% in the tax year ending 2022 to £580 million, returning to near pre-pandemic levels observed in the tax year ending 2020. Income Tax from interest in possession trusts also increased to pre-pandemic levels of £140 million observed in the tax year ending 2020.

Capital Gains Tax payable saw a second consecutive tax year of substantial increases, reaching a high of £1,055 million in the tax year ending 2022. Historic Capital Gains Tax data shows relatively volatile results with some occasional higher peaks (see figure 9) - it is possible that this is another of those peaks and may not be a sustained upward trend. The ‘Key Points’ section of the August 2023 Capital Gains Tax statistics comments on wider factors which may have caused Capital Gains Tax payable to increase overall during the tax year ending 2022. This includes an increase in activity in the residential property market following the first year of the COVID-19 pandemic and more people using the Capital Gains Tax on UK property service since its introduction in the tax year ending 2021.

Table: Breakdown of Income Tax liability and total Capital Gains Tax by trust type

Tax year ending Income Tax - all trusts (£ million) Income Tax - trusts paying tax at the special trust rate (£ million) Income Tax - interest in possession trusts (£ million) Income Tax - other - estates, charitable trusts etc (£ million) Capital Gains Tax (£ million)
2012 645 475 145 25 410
2013 650 475 145 30 345
2014 675 485 160 35 545
2015 735 545 155 35 805
2016 790 575 175 40 625
2017 625 455 130 35 655
2018 690 505 140 40 660
2019 730 530 160 40 735
2020 770 585 140 40 625
2021 675 510 120 40 830
2022 765 580 140 40 1,055

About these statistics

This is a National Statistics publication produced by HM Revenue and Customs (HMRC) showing the number of full Self Assessment returns made in respect of trusts and estates. Their income and tax paid are based on information from HMRC’s administrative systems.

Figures are updated annually and were last published in October 2022. Statistics for the tax year ending 2022 are included for the first time in the current publication. Figures for previous years have been revised due to availability of further data; see section 1.9 of the accompanying trust statistics background quality report for further information about these revisions.

The TRS statistics published last year (October 2022 release) included trusts and estates which had already closed in figure 1 and supplementary table 1. Such trusts and estates have now been excluded from figures in this release. Some figures up to and including the 12-month period ending March 2022 have decreased as a result. In general, trust and estate registration figures for earlier years are expected to decrease slightly with time as trusts and estates close.

This publication contains statistics on chargeable gains and Capital Gains Tax. The chargeable gains figures presented are the gains above the tax-free allowance, also known as the Annual Exempt Amount (AEA). Further information on the AEA is available at Capital Gains Tax rates and allowances. Due to changes to the chargeable gain and Capital Gains Tax reporting requirements for trusts with disposals of residential property in the tax year ending 2021, this information can be reported separately from Self Assessment returns. This publication uses a separate data source to include Capital Gains Tax and chargeable capital gains from residential property filed via the Capital Gains Tax on UK property service in the tax years ending 2021 and 2022. This may cause capital gains and Capital Gains Tax figures to be more prone to revisions in later publications. For the tax year ending 2022, we excluded records for around 520 trusts from the new data source accounting for under £10 million Capital Gains Tax liability and £35 million chargeable gains, since they do not exist in our Self Assessment return data. For the tax year ending 2021, we exclude records for around 210 trusts which account for under £5 million Capital Gains Tax liability and £15 million chargeable gains. We exclude non-resident chargeable gains relating to the disposal of UK property from the chargeable gains statistics in this release. We will consider whether this can be included in this publication in future years.

Rounding

The amounts of money shown in the tables have been rounded to the nearest £5 million, while numbers of trusts and estates in TRS-derived tables have been rounded to the nearest 1,000 and to the nearest 500 in all other tables (except for the lowest income categories in tables 3 and 5). The rounding of numbers in the TRS-derived tables reflects a degree of uncertainty in the number of open trusts and estates as the cleaning process is unable to deal with all possible circumstances in which a trust or estate may be recorded more than once within raw TRS data.

Some figures and percentages presented in the commentary have been calculated based on unrounded numbers and therefore may not sum up to the rounded totals shown in the tables.

Revisions strategy

This publication includes figures for the tax year ending 2022 for the first time plus revised figures for earlier years back to the tax year ending 2019, reflecting any Self Assessment tax returns for these years received since statistics were last published and changes to the way the data has been extracted from Self Assessment administrative systems. The method for counting registered trusts and estates has changed since the previous publication and now exclude from these figures records that have subsequently been marked as closed or obsolete.

The table below shows changes since last publication. Numbers may not sum due to rounding.

Table: Year-to-year revisions - changes in number or in £ million

Tax year ending Number of trusts and estates Total Income Tax Total Capital Gains Tax
2019 890 0 0
2020 1,810 5 5
2021 4,760 25 20

Table: Year-to-year revisions - percentage change

Tax year ending Number of trusts and estates Total Income Tax Total Capital Gains Tax
2019 0.6% 0.1% 0.2%
2020 1.2% 0.8% 0.4%
2021 3.4% 3.9% 2.4%