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HMRC internal manual

Trusts, Settlements and Estates Manual

Non-resident trusts: new non-resident trust: completed form 50FS not received -

If form 50FS is issued but a completed form 50FS is not received, HMRC can issue a formal notice requiring such particulars for the purpose of considering liabilities which may arise on the settlors or beneficiaries of the trust under the transfer of assets legislation (ITA/S748) or from the attribution of trust gains to beneficiaries (TCGA 1992/S98).

Before you issue a formal notice, refer to SPT Personal Tax International Advisory for agreement that this course of action is appropriate, using Technical Help on the TSEM left bar (available to HMRC users only)