HMRC’s guidance on “Register your client’s trust” states that if Trust Register information changes, you must tell HMRC by 31 January of the tax year after either:
•the trust has been set up
•it starts to make income or chargeable gains, if this is later (a simplification of the UK taxes that are set out in regulation 45(14) of the legislation)
HMRC’s guidance to question 20 (from SA950) states:
You’ll need to update the Trust Register with details of all the trustees, personal representatives, beneficiaries, members of the class of beneficiaries, settlors, protectors, agents or additions to the people associated with the trust. If you’ve updated the Trust Register, or confirmed there are no changes, please tick in the box at Q20.1. You should ensure that the Trust Register is up to date and accurate at the same time as you complete the SA900.
It is not yet possible to update the Trust Register, as HMRC have not added that functionality to the website, and changes to the lead trustee have to be notified by post.
Has anyone received feedback from HMRC that 2018 tax returns will not be queried if submitted now with box 20.1 unticked, but with a white space note that the Trust Register will be updated or confirmation that there are no changes by 31 January 2019?