The scale of trusts in Self Assessment
The Self Assessment series measures trusts and estates that report income or gains to HMRC. It understates the total number of trusts in existence, because many trusts hold assets that generate no taxable income in a given year and so file no return. The count fell through the late 2010s, reached 148,500 in the 2020-21 and 2021-22 tax years, then recovered to 157,500 in the 2023-24 tax year.
Trusts and estates filing Self Assessment returns, by type, United Kingdom, tax years ending 5 April
| Tax year ending | Total | Special trust rate | Interest in possession | Other |
|---|
| 2018 (2017-18) | 156,000 | 89,500 | 50,500 | 16,500 |
| 2019 (2018-19) | 157,000 | 90,500 | 50,500 | 16,000 |
| 2020 (2019-20) | 152,500 | 87,500 | 49,000 | 16,000 |
| 2021 (2020-21) | 148,500 | 85,000 | 46,500 | 17,500 |
| 2022 (2021-22) | 148,500 | 84,500 | 45,500 | 19,000 |
| 2023 (2022-23) | 153,500 | 84,500 | 49,000 | 20,500 |
| 2024 (2023-24) | 157,500 | 84,500 | 52,000 | 21,000 |
Source: HMRC, Statistics on trusts in the UK, December 2025. Figures rounded by HMRC to the nearest 500; note that HMRC's Table 2 prints the 2023-24 total as 157,000, while HMRC's narrative rounds it to 157,500 (the headline used here), a one-step rounding difference. "Special trust rate" broadly covers discretionary and accumulation trusts; "interest in possession" trusts give a beneficiary a present right to income.
The recovery since 2021-22 is driven by interest in possession trusts, which rose from 45,500 to 52,000 filings over two years. The number of special trust rate trusts has been flat at 84,500 for three years. Limitation: the series counts returns, not distinct trusts, and combines trusts with deceased estates, so it is not a clean census of trusts alone.
The Trust Registration Service
The Trust Registration Service is a separate dataset with a different purpose. It exists to record beneficial ownership, not to assess tax, and its scope was widened by the Fifth Money Laundering Directive as implemented in UK regulations, which required most existing express trusts to register by 1 September 2022 whether or not they were liable to tax. That deadline explains the shape of the registration data.
New Trust Registration Service registrations, 12 months to 31 March, United Kingdom (registrations still recorded as open at HMRC's 29 August 2025 extract)
| Year to 31 March | Total new registrations | of which non-taxable | of which estates |
|---|
| 2022 | 27,000 | 15,000 | 4,000 |
| 2023 | 439,000 | 399,000 | 4,000 |
| 2024 | 105,000 | 90,000 | 5,000 |
| 2025 | 113,000 | 94,000 | 8,000 |
Source: HMRC, Statistics on trusts in the UK, December 2025, Table 1. These figures count registrations made in each 12-month period that were still recorded as open at HMRC's data extract of 29 August 2025, and this is the only basis on which HMRC publishes the non-taxable and estate split. On this basis the latest year rose about 8% (105,000 to 113,000). HMRC's Figure 1 headline commentary quotes a slightly higher rounded count for the latest year (121,000, described as up about 5% on 115,000) but does not break that count down by non-taxable trusts and estates. Registration deadline basis: HMRC, Register a trust as a trustee.
The 439,000 registrations in the year to March 2023 are a one-off, produced by the compliance deadline rather than by new trusts being created. Registrations have since settled to around 105,000 to 113,000 a year on the registered-and-still-open basis. The stock of open registrations reached an estimated 835,000 at 31 March 2025, with roughly one-seventh of that total registered during the latest year. Limitation: the register includes estates and dormant or non-income trusts, so it cannot be read as a count of active, income-producing trusts.
Trust income and tax
Trust income and the tax on it both rose in the 2023-24 tax year, but for different reasons and in different directions across taxes. Income Tax rose steeply while Capital Gains Tax fell.
Trust and estate tax reported, United Kingdom, by tax year (£ million)
| Tax year | Total income (£m) | Income Tax (£m) | Capital Gains Tax (£m) |
|---|
| 2020-21 | n/a | 680 | 835 |
| 2021-22 | n/a | 810 | 1,080 |
| 2022-23 | 3,190 | 800 | 790 |
| 2023-24 | 3,630 | 1,010 | 605 |
Source: HMRC, Statistics on trusts in the UK, December 2025. Monetary figures rounded by HMRC to the nearest £5 million. Total income for years before 2022-23 is not stated in the figures reviewed and is shown as "n/a".
HMRC attributes much of the 26% rise in Income Tax to basis period reform, under which trusts aligned their accounting periods to the tax year, pulling additional income into the 2023-24 return. That makes the year-on-year jump partly a timing effect rather than pure growth. Limitation: because of basis period reform, HMRC advises that 2023-24 income and Income Tax are not cleanly comparable with earlier years.
Inheritance Tax on trusts
Relevant property trusts, broadly most lifetime trusts created since the 2006 reforms, face an Inheritance Tax charge at each ten-year anniversary and when property leaves the trust. HMRC records these separately from the income and gains series. The amounts are small relative to headline Inheritance Tax.
Inheritance Tax charges on trusts, United Kingdom
| Charge type | Scale | Basis |
|---|
| Ten-year anniversary charge (peak) | 2,030 charges, about £177m tax | 2017-18 tax year peak; has fallen since |
| Entry charge (into trust) | Fewer than 80 a year, under £8m a year | Average over 2011 to 2025 |
| Exit charge (out of trust) | Around £15m a year | Average over 2011 to 2025 |
Source: HMRC, Inheritance Tax liabilities statistics: commentary, updated 30 July 2026 (tables 12.7a to 12.7c). The maximum effective ten-year rate is 6% of relevant property above the available nil-rate band.
For context, total Inheritance Tax receipts were £8.2 billion in the 2024-25 tax year (HMRC tax and NIC receipts bulletin, released 23 April 2025), and 30,400 estates were liable to Inheritance Tax in 2023-24 (HMRC, Inheritance Tax liabilities statistics, updated 30 July 2026). Trust charges are a minor line within that total. Limitation: HMRC flags 2023-24 and 2024-25 trust-charge estimates as incomplete because accounts are still being submitted, so recent-year figures may rise.
Terms used. A
relevant property trust is a trust whose assets fall within the periodic Inheritance Tax regime, which since Finance Act 2006 covers most lifetime discretionary and many interest in possession trusts. A
ten-year anniversary charge is an Inheritance Tax charge of up to 6% on the value of relevant property above the nil-rate band, levied every ten years. An
exit charge arises when property leaves the trust between anniversaries.
Note: the standard nil-rate band is £325,000 and thresholds are frozen until 5 April 2031 (
gov.uk, as at July 2026, subject to change).
Who holds the income
The income distribution tables show that a small number of trusts account for most trust income, while the majority report very little. This holds across both main trust types.
Interest in possession trusts by income band, United Kingdom, 2023-24 tax year
| Income band | Number of trusts | Income (£m) |
|---|
| Less than £1,000 | 21,500 | 5 |
| £1,000 to £5,000 | 11,000 | 30 |
| £5,000 to £10,000 | 5,500 | 40 |
| £10,000 to £20,000 | 4,500 | 60 |
| £20,000 to £50,000 | 4,000 | 120 |
| £50,000 to £100,000 | 2,000 | 120 |
| £100,000 or more | 3,000 | 885 |
Source: HMRC, Statistics on trusts in the UK, December 2025. Figures rounded by HMRC.
The top band, 3,000 trusts with income of £100,000 or more, holds about £885 million of the £1.23 billion of interest in possession income, while more than 40% of these trusts report under £1,000 of income. The special trust rate tables show the same pattern, with about 4,000 trusts in the £100,000-plus band accounting for roughly £1,240 million of that type's £1.82 billion income. Estimate: on these HMRC totals the top band works out at about 72% of interest in possession income and about 68% of special trust rate income; those shares are a Fairchild Oldfield calculation, set out with its method in the Original synthesis, not an HMRC figure. Limitation: income is not wealth; a trust with modest income may hold substantial capital that produces little taxable return.
