Trust Register - non-UK agent

I have posted this on the other Trust Register threads but haven’t had a response so am posting this as a new topic. Are there any other non-UK agents trying to register?

Being in the Channel Islands, as a firm we do not have our own UK UTR or CT reference. I have therefore been unable to get past this part of registering as an agent for the Trust Register.

I have contacted HMRC several times in various ways, and the conclusion is that the Trust Register software doesn’t allow non-UK agents yet, so for 2016/17 we need to register each trust individually as trustee (separate Government Gateways etc for each). HMRC suggested that we obtain authority from the trustees to be able to do this (he did apologise and blamed the software). The official email response is simply, “The service is currently only open to UK agencies. We will provide access for overseas agencies in 2018/19.” - no solution suggested!

To register each trust individually (as trustee) in not strictly correct, and will greatly prolong the (already very time consuming) process. Not only do we have trust clients with 5 December and 31 January Trust Register deadlines, we also have new trust clients that need UTRs so we can submit 2016/17 tax returns by 31 January.

Anyone else in this position? Thanks in advance for any responses!

Helen Salisbury

Saffery Champness

Copying the replies on this topic in another thread:

Helen Salisbury
Saffery Champness


As you have discovered overseas agents cannot currently set up an agent services account. HMRC is providing a workaround for this. Any overseas agent without a UTR should contact the trusts helpline (+44 300 123 1072) and request a data capture sheet to gather the information and send back to HMRC (this is only available to overseas agents).

Sue Moore,


Many thanks for your post Sue Moore. I have just come off the phone with HMRC’s trust’s helpline. The person I spoke to initially insisted there was no work around for non-UK agents but I persisted and was put through to someone else who is acting as the liaison between the trust’s helpline and the trust register. He was very helpful and confirmed that we could register our trusts in paper format on a “data capture” sheet. He advised we may have to add pages as required (extra beneficiaries etc.) and we would also need to add a sheet with our agents details (Agent ID, name and address). He is sending me the form by post which comes with a 64-8 and it is to be submitted to the Nottingham Office at Ferrers House. He did note this is option is only available to non-UK agents who don’t have a UK office. If there is a UK office any registrations should be done online through that office.

Mandy Connolly
LTS Tax Limited

Thank you so much Sue Moore!

I had to call HMRC another two times, and had to be extremely persistent with the above information you and Mandy kindly provided. Eventually I spoke to an extremely helpful person who is sending us the paper form, as noted above. This did take some persistence though - everyone else I spoke to/emailed at HMRC didn’t know about this workaround for non-UK agents.

Apparently the paper form (presumably one for each trust) is 19 pages long, and we may need to photocopy parts of it in order to provide the necessary information. Then HMRC Nottingham have to manually input this onto the online Trust Register! The gentleman I spoke to did apologise for this (hopefully temporary) workaround - it is hoped that we will have online access ‘next year’. Frankly I am staggered that this is the ‘solution’!

Thanks again both for your help, much appreciated.

Helen Salisbury
Saffery Champness

My clients who are offshore trust service providers have asked me to assist on the trust registration side of things.
So they don’t need to register as agents.

Before agent access was granted, I was planning to register the trusts individually on behalf of the trustees.

Any other way, it would be a difficult situation for the offshore service providers.

Sameera Nathoo

It would also be good to get people’s thoughts on how they propose to not breach data protection laws in the jurisdiction of residence of the non-UK trustees when reporting information on data subjects? My understanding of data protection laws is that information regarding data subjects (individuals for whom we hold data) is required to be reported if there is domestic legislation requiring the reporting. However, the UK legislation is not domestic legislation to a non-UK trustee. It seems the legislation requires domestic legislation to be broken in order to report.

We want to be able to comply, we don’t want to break the law, either in the UK or in our domestic jurisdictions, but at present it seems we will have to choose which is “less worse” to break…we are between a rock and a hard place. Any thoughts would be welcomed.

We are looking to talk with the Information Commissioner in each jurisdiction to see what we can do.

I think the paper data collection forms will be helpful in that regard as you can report all the information you are able to legally report for now (i.e. take all possible steps to comply) while this data protection issue is resolved.

Monica Dixie
Equiom Solutions Limited