Trust structures are frequently used in Cyprus for succession planning, asset protection, family wealth management and the orderly holding of investments. Where a Cyprus trust holds assets situated outside Cyprus, however, its trustees must consider not only the law governing the trust but also the regulatory and reporting requirements of every jurisdiction with which the structure is connected.
A significant development now concerns Cyprus trusts holding land or property in the United Kingdom. Amendments to the United Kingdom’s anti-money laundering framework have extended the scope of the Trust Registration Service to certain non-UK trusts that acquired UK land before 6th of October 2020. Trustees of affected structures will be required to register the trust with HM Revenue & Customs by the 1st of September 2027.
This represents an important change for older trust structures. The fact that a trust is established or administered in Cyprus, has non-UK trustees or has no current UK tax liability does not, by itself, remove the registration obligation.
The UK Trust Registration Service
The Trust Registration Service, commonly referred to as the TRS, is the United Kingdom’s register of trusts. It is administered by HM Revenue & Customs and forms part of the United Kingdom’s broader framework for preventing money laundering and terrorist financing.
The TRS was initially associated principally with trusts having UK tax liabilities. Its scope was subsequently expanded to include a wider category of taxable and non-taxable express trusts, including certain trusts established outside the United Kingdom but having specified connections with the country.
A trust may therefore be required to register even where no UK tax is presently payable. Registration under the TRS should not be treated purely as a tax-filing matter. It is also a beneficial ownership and anti-money laundering obligation intended to provide competent authorities with information concerning trusts and the individuals who establish, control or benefit from them.
Extension to Older UK Property Holdings
Non-UK express trusts that acquired UK land on or after 6 October 2020 were already generally within the scope of the TRS, subject to the applicable statutory conditions and exclusions.
The revised rules extend the registration requirement to non-UK express trusts that acquired an interest in UK land before the 6th of October 2020, provided that the trust continued to hold that interest on 30 June 2026. Trustees falling within this category must register the trust by the 1st of September 2027.
The relevant acquisition must ordinarily have been made directly by the trustees. HMRC’s guidance refers to circumstances in which one or more trustees are registered as the proprietor or owner of the relevant freehold or qualifying leasehold interest in the appropriate land register for England and Wales, Scotland or Northern Ireland.
This distinction is important. A trust directly holding UK land through its trustees is not necessarily in the same position as a trust holding shares in a company that owns UK property. Structures involving corporate ownership must be examined separately, including in relation to the United Kingdom’s Register of Overseas Entities and any other applicable beneficial ownership, tax or reporting requirements.
The crucial review date is the 30th of June 2026. Where UK land acquired before 6 October 2020 had already been disposed of before that date, the historic ownership alone does not trigger registration under this particular extension. Where the land remained held on the 30th of June 2026, the trust is brought within the expanded scope and must be considered for registration.
Why the Change Matters for Cyprus Trusts
A Cyprus trust may be treated as a non-UK trust for TRS purposes, depending on the residence of its trustees and, in certain circumstances, the residence status of its settlor. The applicable classification must be assessed under the UK rules rather than assumed solely from the governing law of the trust or the location in which it is administered.
Accordingly, the first step should be to identify all Cyprus trusts within a trustee’s or service provider’s portfolio that directly hold, or previously held, interests in UK land.
The review should establish when the property was acquired, who appears as its registered legal owner and whether the interest continued to be held on 30th of June 2026. It should also determine whether the trust has already been registered with the TRS for another reason, including a UK tax liability, a more recent acquisition of UK land or, where at least one trustee is UK-resident, the commencement of a qualifying business relationship in the United Kingdom.
Existing registration should not automatically be assumed to resolve every compliance issue. The information appearing on the TRS must remain accurate and may need to be updated where changes have occurred in the trustees, beneficiaries, controlling persons or other reportable particulars.
Information Required for Registration
Registration ordinarily requires information concerning the trust itself and the persons associated with it. The exact information required will depend on the trust’s circumstances and whether it is taxable in the United Kingdom.
Information concerning the trust may include its name, date of creation, governing law, legal nature and country of administration. HMRC may also require information concerning the circumstances that create the trust’s connection with the United Kingdom.
Details may be required for the lead trustee and every other trustee, including names, dates of birth, countries of residence and nationalities. Information must also generally be provided concerning the settlor or settlors, named beneficiaries, classes of beneficiaries and any individual or entity exercising control over the trust.
The concept of control extends beyond the formally appointed trustees. Depending on the terms of the trust instrument, a protector or another person may be reportable where that person has the power to direct, withhold consent to or veto the exercise of particular trust powers.
Potential beneficiaries identified in a letter of wishes or another document connected with the trust may also require consideration. Letters of wishes should therefore not be treated as irrelevant merely because they are not legally binding in the same manner as the trust deed.
Where an individual does not have the relevant UK identification or tax reference number, additional address, passport or identity-card information may be required. Taxable trusts may also be required to provide further information concerning the trust’s assets and UK tax liabilities.
The Need for an Early Records Review
Although the deadline of 1 September 2027 may appear distant, trustees should not postpone their review.
Older trusts may have undergone numerous changes since their creation. Trustees may have retired or been appointed, settlors may have died, beneficiaries may have changed residence or nationality, and supplemental deeds may have modified powers or beneficial classes. Property may also have been transferred, refinanced or restructured through underlying entities.
The registration exercise should therefore begin with a review of the trust deed, all supplemental and appointment deeds, letters of wishes, property records and relevant corporate documentation. Current identification and verification documents should be obtained for the persons whose particulars must be reported. Residence and nationality information should be checked rather than reproduced automatically from historical compliance files.
The trust records maintained in Cyprus should also be compared with the information intended to be submitted to HMRC. Inconsistent names, dates, capacities or beneficial ownership classifications may create avoidable questions and may indicate that one or more compliance records have not been updated.
HMRC has stated that the TRS online service is not yet able to accept registrations from non-UK trusts brought into scope solely because they held UK land acquired before 6 October 2020. Further guidance will be issued once the necessary system changes have been completed. The present inability to file does not, however, remove the underlying obligation or justify delaying the preparatory review.
Cyprus and UK Registration Are Separate Obligations
Cyprus maintains its own Register of Beneficial Owners of Express Trusts and Similar Legal Arrangements, commonly known as CyTBOR, under the administration of the Cyprus Securities and Exchange Commission.
The Cyprus framework was amended further during 2026, including changes concerning access to beneficial ownership information. General public access has been removed, while access may be granted to persons or organisations able to demonstrate a legitimate interest in accordance with the applicable statutory framework.
These Cyprus developments form part of the broader European movement towards greater transparency in trust and beneficial ownership arrangements. They do not, however, replace or satisfy the separate UK registration obligation.
A Cyprus trust may consequently be subject to reporting or record-keeping requirements in both jurisdictions. Registration in CyTBOR does not amount to registration with HMRC, and information appearing in one register will not necessarily be transferred automatically to the other. Trustees must assess each regime independently while ensuring that the information reported across jurisdictions remains accurate and consistent.
Consequences of Non-Compliance
The primary responsibility for TRS registration rests with the trustees. Although an agent may be appointed to assist with the process, trustees remain responsible for ensuring that the trust is registered within the applicable period and that the information submitted is complete and accurate.
HMRC’s published approach indicates that penalties are generally considered on a case-by-case basis rather than imposed automatically for every late registration. Nevertheless, a penalty of up to £5,000 may be charged where a registrable trust remains unregistered, particularly where trustees fail to act following notification or provide inaccurate information and do not correct it.
Non-compliance may also create practical difficulties when dealing with banks, professional advisers, purchasers, lenders and other regulated parties. Such parties may request evidence of registration or raise discrepancies between the information supplied to HMRC and the trust’s existing due diligence records.
Practical Next Steps
Cyprus trustees and fiduciary service providers should now identify every trust under their administration that has a present or historic connection with UK land. For each trust, the date and nature of the acquisition, the identity of the registered legal owner and the ownership position as at 30 June 2026 should be established.
Where the trust falls within the extended rules, the relevant constitutional, property and due diligence documentation should be assembled and reviewed. Any outdated or inconsistent information should be corrected in the trust’s internal records before registration is attempted.
Trustees should also monitor HMRC announcements concerning the date on which the TRS will begin accepting registrations in this new category. Once the system becomes available, sufficient time should be allowed to address technical issues, obtain missing information and resolve any uncertainty concerning the persons who must be reported.
Conclusion
The extension of the UK Trust Registration Service to older property-holding structures is particularly relevant to Cyprus trusts used for international asset and succession planning.
A non-UK trust that acquired UK land before 6 October 2020 and continued to hold that interest on 30 June 2026 may now be required to register with HMRC by 1 September 2027, even if the trust has no current UK tax liability.
The appropriate response is not simply to await the opening of the registration system. Trustees should use the intervening period to examine the structure, verify its UK property interests, identify all reportable persons and ensure that the trust’s constitutional and compliance records are complete and consistent.
Early preparation will reduce the risk of inaccurate filings, last-minute difficulties and inconsistencies between the trust’s obligations in Cyprus and those arising in the United Kingdom.
This article is intended to provide general information and does not constitute legal or tax advice. Specific advice should be obtained in relation to the circumstances of each trust.
For further information or legal assistance regarding compliance with the above requirements, please do not hesitate to contact us at info@kpklegal.com
Author
Maria Hadjisavva
Senior Advocate, KPK Legal