Technical article
UK, Canada and Australia: What You File When the Trust Sits Abroad
A Canadian trust files Form T3, with Schedule 15 owner information, 90 days after its year end.
Imagine three friends who have all retired well. One lives in England, one in Ontario and one in Queensland. Each hears about a trust held in another country and asks the same thing: what would I have to tell my own tax office?
The answers differ by country. Here is what the tax offices' own pages say, and it is a short first look, not a full guide.
| Country | What the tax office asks for, and when |
|---|---|
| United Kingdom | Registration on the Trust Registration Service for a trust that pays UK tax or owes UK inheritance tax, within 90 days for a new taxable trust |
| Canada | Form T1141 from a resident who sends property to a non-resident trust, by the normal filing date; Form T3 with Schedule 15 owner details for a Canadian trust, within 90 days of year end |
| Australia | The transferor trust rules, which tax a resident on certain profits of a non-resident trust |
United Kingdom
A trust that pays UK tax or owes UK inheritance tax goes on the Trust Registration Service. New taxable trusts register within 90 days. Failure can bring a penalty of GBP 5,000 (about US$6,500). Non-taxable trusts created after 6 October 2020 also had to register within 90 days.
The larger change is about inheritance tax. From 6 April 2025, settled assets sit outside UK inheritance tax only while the person who settled them is not a long-term UK resident. That applies whatever the date the assets were settled. If the settlor dies as a long-term UK resident, all the settled assets stay in scope for the life of the trust.
Canada
A Canadian resident who sends property to a non-resident trust files Form T1141 by the normal filing date. A Canadian trust files Form T3, with Schedule 15 owner information, 90 days after its year end. For 2025 year ends, the Canada Revenue Agency does not expect bare trusts to file the T3 or Schedule 15. A Canadian who contributes can also cause the non-resident trust to count as resident, under section 94 of the tax act.
Australia
A resident who sends property or services to a non-resident trust, including by creating it, can be taxed on certain trust profits under the transferor trust rules. A resident beneficiary may face an interest charge on some distributions. The Australian Taxation Office guide on this is from 2010. Australian trusts file their own trust tax return.
You might say: "These are three short summaries, and my case is not simple." That is a fair view. The pages here are official, tier A, and they give the headline rules. The detail for your own years of residence sits on the official pages.
You could take one question to your own tax office or adviser: does this trust count as mine for tax, and which form carries it? The same trust can be treated differently in each of these countries. You could also ask the trustee which of its own records go to your tax office each year.
This touches family. In the UK, the inheritance tax rule follows the settlor's residence at death, so what children and grandchildren receive can depend on where the settlor lived.
If you have filed for a trust abroad in one of these countries, what did the first year teach you? Share it here. Someone in the same position may be glad to read it.
Figures are estimates for planning, based on public data. Date read: October 2026.
Sources
- GOV.UK, register your clients' trust (A)
- HM Revenue and Customs Inheritance Tax Manual IHTM47050 (A)
- Canada Revenue Agency, information return for contributions to non-resident trusts (A)
- Australian Taxation Office, foreign income return guide 2010 (A)
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