TRSM22020 - Types of trust that need to be registered: contents: registrable express trusts: contents: additional registration requirements for non-UK express trusts
Acquisition of UK land by non-UK trusts
Under Reg 42 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, non-UK express trusts, the acquisition of UK land by the trustees triggers the requirement for registration when:
the land was acquired on or after 6 October 2020
the land was acquired before 6 October 2020 and still held by the trust on or after 30 June 2026
The trustees of a non-UK trust are treated as acquiring UK land when one or more of the trustees become registered:
with HM Land Registry as the proprietor of a freehold estate in land or of a leasehold estate in land granted for a term of more than 7 years from the date of the grant;
with the Land Register of Scotland as the proprietor of land or as the tenant under a lease; or
with the Land Registry of Northern Ireland as the owner of a freehold estate in land or of a leasehold estate in land granted for a term of more than 21 years from the date of the grant.
The above definition means that to be treated as acquiring UK land, the trustees must acquire the land directly.
To “hold land or property” for the purposes of this guidance means that the trustee remains the legal signatory to any of the above listed acquisitions.
Note that this condition is only relevant for non-UK express trusts. UK express trusts are required to register (subject to the exclusions at TRSM23000) regardless of whether or not the trustees have acquired UK land.
Example
The trustees of the non –UK ABC Trust acquired the freehold to a property in London on 1 January 2020, the property was later sold on 2 May 2024. The requirement for trusts to register having acquired UK land prior to 6 October 2020 came into force on 30 June 2026. As this acquisition of UK land was before 6 October 2020 and the land was not held on or after 30 June 2026, this does not trigger the requirement to register on the Trust Registration Service (TRS).
On 2 January 2020, the trustees acquired the freehold to a second property in London, and the trust still holds this property. As this acquisition occurred before 6 October 2020 and this property was still held on 30 June 2026, these circumstances trigger the requirement for the trust to register on TRS.
Business relationship
Trustees of a non-UK express trust with at least one UK resident trustee must register when the trustees, in their capacity as trustees of the trust, enter into a business relationship with a UK relevant person on or after 6 October 2020. See TRSM24000 for further information on business relationships.
Note that this condition is only relevant for non-UK express trusts if one or more of the trustees are UK resident.
NOTE: As of 30th June 2026, non-UK trusts holding UK land acquired pre-6 October 2020, and still held that land on the 30th June 2026 are required to register on TRS; trustees in this position must register by 1 Sep 2027. The IT is being updated to support these additional registrations, and further guidance on when trustees in this position can commence registration will be issued in due course.