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HMRC internal manual

VAT Registration

Entity to be registered: trusts and pension funds: trustee activities not requiring separate VAT treatment

The separation of trustee and non-trustee activities is preferable and will be the norm.


  • trust activities are so closely connected to those of the normal business as to be part of it (this may occur when a taxable person is also the sole trustee of a trust), or
  • persons are the beneficiaries as well as trustees of a trust

only one registration is necessary.

However, this is purely a matter of policy and we have no power to enforce it. The lack of legal provisions for the registration of trusts and trustees means that we are unable to resist applications for the separate registration of trusts, even where each of those trusts has the same trustees.