Pension Schemes and Life Assurance policies held in trust


I've been asked this question and I need some help!

Do Pension Schemes and Life Assurance policies held in trust need to be registered with the UK Trust Register? The person asking states that their understanding was that they only had to register if the trustees had a tax liability, but they understand this is this is about to change.

Does anyone have any ideas?

Thanks in advance!


  • I think if the pension is already registered with HMRC via pension schemes online then they are OK - no need for dual registration.

    Who knows what will happen under 5MLD - at the moment it looks like all life assurance in trust will need to register too.

  • Current Position.
    Pension Scheme registered with HMRC by scheme provider so no need to do anything.
    Life policies (or any other asset held in trust) - trust does not need to be registered with HMRC unless a tax liability arises.

    Future Position
    As a result of 5MLD all express trusts (so any trust that is not a statutory trust) would need to be registered with HMRC. However, pension schemes and pure life policies have been exempted from this process (as have some others).
    Bare Trusts are under discussion.
    The current deadline is now 2022 (May, I think).
    So, for the time being, no need to register existing or new trusts unless a tax liability arises.
    Don't rush to register anything until clarification regarding bare trusts (and possibly some other exemptions depending on how the ongoing discussions go).

    See STEP:

  • good stuff @richardgough
    Looks like common sense might prevail.

  • Yes, in respect of life policies.
    However, I don't expect to see any exemption for most investment based trusts - discretionary or otherwise - a this is all about money-laundering prevention and not tax.
    So all the DGT, Gift and Loan trust we've done will need to be registered (eventually).
    It will be interesting to see the outcome regarding Bare Trusts.

  • FATCA wasn't too much of a headache - hopefully this will be the same!

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