IEIM400990 - Non-Reporting Financial Institutions: Trustee Documented Trust

NRFI: Trustee Documented Trust

Trustee-documented trusts are Non-Reporting Financial Institutions (NRFI) for both regimes.

A trustee-documented trust (TDT) is a trust that is a Financial Institution [see IEIM400600] where the trustee of the trust is itself a Reporting Financial Institution [see IEIM402100] and reports all the information required in respect of the Reportable Accounts [see IEIM401520] of the trust.  In such a case, the trust itself becomes a Non-Reporting Financial Institution. 

Registration  

Although trustee-documented trusts are NRFIs, they are required to register for AEOI by the later of 31 December 2025 or 31 January following the calendar year in which they first fall within the definition of TDT for FATCA or CRS purposes. This is because HMRC would not otherwise have complete visibility over the population of trustee-documented trusts, the trustees of which have due diligence and potential reporting obligations in respect of the trusts they manage.   

Since a TDT is not required to register with the US Internal Revenue Service for FATCA, it will not usually have a Global Intermediary Identification  Number (GIIN). For registration with HMRC, a TDT should use the default GIIN of 000000.00000.LE.000   

Reporting  

There are differences in the way TDTs are reported for CRS and FATCA, as explained below. For the reporting year 2026, it will not be possible to report accounts of the same TDT for both CRS and FATCA purposes in the same submission. Where a TDT has reportable accounts for both CRS and FATCA, separate submissions will need to be made. 

For the reporting year 2027 onwards, CRS and FATCA reporting will be made on separate schemas.   

CRS 

The trustee must report information as the TDT would have reported it. Therefore, a report for a TDT should show the name of the TDT as the Reporting Financial Institution.  

FATCA 

The trustee must report information using the trustee’s name as the Reporting Financial Institution and the trustee’s GIIN.   

The trustee must identify, when reporting, the trustee-documented trust in respect of which it fulfils the reporting and due diligence obligations. This should be done by including the trust name in the account number or account identifier section when completing the return for the trust on the HMRC portal. For an xml report the trust name should be included in the account number or account identifier field of the schema.