The regulations apply to 'relevant trusts.' A relevant trust is a UK trust which is an express trust, or a non-UK trust which is an express trust and also receives income from a source in the UK, or has assets in the UK on which it is liable to pay various taxes. A trust is a 'UK trust' if all the trustees are resident in the UK or if at least one trustee is resident there and the settlor was resident and domiciled there when he set up the trust or added funds to it.

Matthew Giles' recipe for compliance - originally written for pension plans but applicable to all express trusts - is as follows.

Step 1: identify the beneficial owners of the pension plan. The phrase 'beneficial owner' captures:

• all trustees;
• the original sponsoring employer;
• the current plan employers;
• all identifiable pension plan beneficiaries ;
• any categories of undetermined beneficiaries;
• all other individuals who could be said to exercise “control” over the plan. This could capture, for example, the directors of a corporate trustee or a plan actuary whose consent is required to any form of plan amendment.

Step 2: review plan rules to identify any other individuals who might exercise 'control.'

Step 3: collate information required to be kept in respect of beneficial owners who are individuals. This includes:

• full name;
• national insurance number or unique taxpayer reference;
• if the individual does not have a national insurance number or unique taxpayer reference, the individual’s usual residential address. If the address is outside of the UK, passport number or identification card number or equivalent form of identification;
• date of birth; and
• nature of role in relation to the pension plan.

Step 4: collate information required to be kept in respect of beneficial owners who are corporate bodies. This includes:

• corporate/firm name;
• unique taxpayer reference;
• registered principal office;
• legal form of the legal entity and the law by which it is governed;
• if applicable, the name of the register of companies in which the legal entity is entered including details of the EEA State or third country in which it is registered;
• registration number; and
• nature of the entity’s role in relation to the plan.

Step 5: create a written record of the description of the class of persons who are undetermined beneficiaries or potential beneficiaries.

Step 6: create a written record of a contact address for all trustees and plan advisors.

Step 7: find out whether the pension plan or other vehicle constitutes a "taxable relevant trust." This will depend upon whether it is liable to pay any of the following taxes: income tax, capital gains tax, inheritance tax, stamp duty reserve tax, stamp duty land tax, land and buildings transaction tax .

Step 8: if the plan is a taxable relevant trust and the trustees became liable to either income tax or capital gains tax for the first time in the tax year 2016/17, the trustees must register on HMRC’s new Trusts Registration Service by 5 January .

Step 9: if the plan is a taxable relevant trust but either the trustees were not liable for income tax or capital gains tax in the last tax year or they have already paid such taxes in previous tax years, they must register on HMRC’s new Trusts Registration Service by 31 January.

Step 10: add money laundering compliance to the plan’s risk register.