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UK AEOI registration for trusts post‑2025: impact on trustee‑documented trusts, trusts with trust corporation trustees, and lay‑trustee shareholdings; applying the 50% investment and professional management tests

Published on: 28 January 2026

Published by a LexisNexis Private Client expert
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See Q&A: Amendments made to the International Tax Compliance Regulations 2015 (2015 regs) by the International Tax Compliance (Amendment) Regulations 2025 have introduced a new mandatory AEOI registration requirement for certain trusts which are 'specified non-reporting financial institutions'

Following changes to the International Tax Compliance Regulations 2015 (2015 regs) by the International Tax Compliance (Amendment) Regulations 2025, a compulsory AEOI registration obligation now applies to particular trusts treated as ‘specified non-reporting financial institutions’. Is AEOI registration now required in these cases?

  • Trusts with a trust corporation as trustee where less than 50% of trust income derives from investments
  • Trustee‑documented trusts without at least 50% of investments managed by a Discretionary Fund Manager
  • Trusts with individual lay trustees holding shares in a private company that pays substantial dividends

Amendments to the 2015 regs, SI 2015/878 by The International Tax Compliance (Amendment) Regulations 2025, SI 2025/740 introduce a new Automatic Exchange of Information (AEOI) registration duty for trusts falling within ‘specified non‑reporting financial institutions’. Under the 2015 regs, SI 2015/878, reg 24(1) states that a specified non‑reporting financial institution is a non‑reporting financial institution that is a trust as described in Section VIII(B)(1)(e) of the CRS or paragraph II(D) of Annex II...

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