Jurisdictions
Trust vs foundation: compare jurisdictions and structures
Trust vs foundation is the first decision when you pick a structure. A trust splits legal ownership, held by a trustee, from the benefit, held by beneficiaries. A foundation is a legal entity with a council and no owners. Choose up to 4 places below and read the facts for each in one table.
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| Fact |  Hong KongView Hong Kong |  SingaporeView Singapore |  BVIView BVI |  JerseyView Jersey |  UAEView UAE |  Cayman IslandsView Cayman Islands |  GuernseyView Guernsey |  Cook IslandsView Cook Islands |  NevisView Nevis |  SwitzerlandView Switzerland |  Isle of ManView Isle of Man |  PanamaView Panama |  BermudaView Bermuda |  New ZealandView New Zealand |  MauritiusView Mauritius |  LiechtensteinView Liechtenstein |  CyprusView Cyprus |  South DakotaView South Dakota |  NevadaView Nevada |  DelawareView Delaware |  WyomingView Wyoming |  AlaskaView Alaska |  New HampshireView New Hampshire |  TennesseeView Tennessee |  LabuanView Labuan |  BahamasView Bahamas |  BelizeView Belize |  MaltaView Malta |  LuxembourgView Luxembourg |  NetherlandsView Netherlands |  GibraltarView Gibraltar |  AnguillaView Anguilla |  SeychellesView Seychelles |  SamoaView Samoa |  VanuatuView Vanuatu |  BarbadosView Barbados |  Turks and CaicosView Turks and Caicos |  Marshall IslandsView Marshall Islands |  St KittsView St Kitts |  St Vincent and the GrenadinesView St Vincent and the Grenadines |
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| Delivery model | We act as trustee and run the service directly. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | A local partner acts as trustee and we coordinate the service for you. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | We work alongside a local partner who takes a defined role in the trust. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. | A local partner acts as trustee and we coordinate the service for you. |
| Trust structure | – | – | VISTA 2003: special rules for trusts of BVI company sharesBVI Financial Services Commission: Virgin Islands Special Trusts Act (2003) | – | – | – | – | Registered; non-resident beneficiaries; listed company as trustee or power holderAct No. 14 of 1984, section 2 (FSC copy) | Settlor and beneficiaries must at all times be non-residents of NevisNevis FSRC: Trusts | Switzerland has no trust law of its own; a trust is set up under another place's lawFedlex: Swiss federal law | – | A trust must be expressly declared in writing; verbal ones are invalid (art. 4)Organo Judicial (CENDOJ): Ley 1 de 1984 sobre fideicomiso (Gaceta Oficial 19971) | – | – | A trust is of no effect unless created by an instrument in writing (s. 6)Attorney General's Office: Trusts Act (Act 14 of 2001), Revised Laws of Mauritius | Trust (Treuhänderschaft) under the PGR; deed names the trustee and beneficiariesLiechtenstein Law Gazette: Persons and Companies Act (PGR) | International trustCyLaw: International Trusts Law (1992) | – | NRS 166.040: irrevocable writing; no mandatory distributions to the settlorNevada Legislature: NRS Chapter 166, Spendthrift trusts | – | – | – | – | – | – | Foundations Act 2004 and Purpose Trust Act 2004 widened the optionsBahamas Financial Services Board via Legal 500: The Bahamas Toolkit (2025) | – | Trust under Cap. 331; the deed names the trustee and the beneficiariesMalta Ministry for Justice: Trusts and Trustees Act (Cap. 331) | No domestic trust; foreign trusts recognised through the Hague ConventionLegilux: Law of 27 July 2003 on trusts and fiduciary contracts | No domestic trust; foreign trusts recognised through the Hague ConventionHCCH: Convention on the Law Applicable to Trusts and on their Recognition (1985) | – | A Trust (Amendment) Act 2023 and a Special Trust Act are listedAnguilla FSC: Legislation | A Seychelles trust is of no effect unless made in writing (s. 8)Official Gazette: Trusts Act 2021 (Act 34 of 2021) | The Foundations Act 2016 provides for Samoan foundationsPacLII: Foundations Act 2016 (Samoa) | – | International Trusts Act, Cap. 245, is still listedInvest Barbados: Barbados Legislation | Revocable and irrevocable trusts allowed; private trust companies with limitsVisit TCI, Financial Services: Trusts | – | Charitable, spendthrift or protective, unit and common trustsFSRC St Kitts: Types of Trust | – |
| Governing law | Common law and the Trustee Ordinance (Cap. 29)Trustee Ordinance (Cap. 29), Hong Kong e-Legislation | Trustees Act 1967: duty of care (Part 1A), investments (Part 2), powers (Part 3)Singapore Statutes Online: Trustees Act 1967 | Trustee Act (Cap. 303): the general law of trustsBVI Financial Services Commission: Trustee Act (Revised 2020) | Jersey law decides validity and effect of a Jersey trust (Article 9)Jersey Law Website: Trusts (Jersey) Law 1984 | The 2018 Trust Law governs trusts that choose DIFC lawTrust Law 2018, Dubai International Financial Centre (consolidated March 2024) | Trusts Act (2021 Revision), including the STAR regimeWalkers: Cayman Islands STAR Trusts, Reinforcing the Role of Enforcers (2024) | The Trusts (Guernsey) Law, 2007 is the main statute for Guernsey trustsGuernsey Legal Resources: Trusts (Guernsey) Law, 2007 | International Trusts Act 1984 (No. 14), as later amendedAct No. 14 of 1984 (FSC copy) | Nevis International Exempt Trust Ordinance (Cap. 07.03(N))Nevis FSRC: Trusts | – | The Trusts Act 1995 is a core statute for Isle of Man trustsIsle of Man Government: Isle of Man legislation | Law 21 of 2017 (10 May 2017) on fiduciaries; Law 1 of 1984 on trustsOrgano Judicial (CENDOJ): Ley 1 de 1984 sobre fideicomiso (Gaceta Oficial 19971) | Trustee Act 1975; Amendment Act 2025 in force 10 October 2025Carey Olsen via Legal 500: The Trustee Amendment Act 2025, Bermuda (2025) | Trusts Act 2019, in force from 30 January 2021, and the common lawNew Zealand Legislation: Trusts Act 2019 | The Trusts Act (Act 14 of 2001) governs Mauritius trustsAttorney General's Office: Trusts Act (Act 14 of 2001), Revised Laws of Mauritius | Persons and Companies Act (PGR); trusts have their own titleLiechtenstein Law Gazette: Persons and Companies Act (PGR) | International Trusts Law of 1992, as amendedCyLaw: International Trusts Law (1992) | – | – | Qualified Dispositions in Trust Act, 12 Del. C. 3570 to 3576Delaware Code: Title 12, chapter 35, subchapter VI, Qualified Dispositions in Trust | Qualified spendthrift trusts: W.S. 4-10-510 to 4-10-523Wyoming Statutes: Title 4, chapter 10, Uniform Trust Code | A settlor can also be a beneficiary of a spendthrift trust: AS 34.40.110Alaska Statutes: Title 34, chapter 40, Restricting Transfers of Trust Interests | Settlor's interest in an irrevocable spendthrift trust: RSA 564-B:5-505ANew Hampshire Revised Statutes: Creditor's Claim Against a Settlor of an Irrevocable Trust | Investment services trusts: Tennessee Investment Services Act of 2007Tennessee Code: qualified trustee and trust instrument, chapter 16 | Labuan Trusts Act 1996 (Act 554), as amended up to Act A1368 of 2010Laws of Malaysia: Labuan Trusts Act 1996 (Act 554) | Trustee Act 1998 sets trustee powers and beneficiary rightsBahamas Financial Services Board via Legal 500: The Bahamas Toolkit (2025) | Trusts Act, Chapter 202 (Revised Edition 2020)Financial Services Commission Belize: Laws and Amendments | Trusts and Trustees Act (Cap. 331)Malta Ministry for Justice: Trusts and Trustees Act (Cap. 331) | Law of 27 July 2003 on trusts and fiduciary contractsLegilux: Law of 27 July 2003 on trusts and fiduciary contracts | Hague Trusts Convention (1985)HCCH: Convention on the Law Applicable to Trusts and on their Recognition (1985) | Gibraltar trust law includes the Trustees Act and the Trusts (Recognition) Act 1989Laws of Gibraltar: Trusts legislation | Trusts Act 1994Anguilla FSC: Trust sector page | The Trusts Act (Act 34 of 2021) governs Seychelles trustsOfficial Gazette: Trusts Act 2021 (Act 34 of 2021) | Trusts Act 2014, with a 2016 amendment, and the common lawPacLII: Trusts Act 2014 (Samoa) | No Vanuatu trust statute is listed in the PacLII consolidated Acts indexPacLII: Vanuatu consolidated legislation index | Trusts (Miscellaneous Provisions) Act 2018-49 and Trustee Act Cap. 250Invest Barbados: Barbados Legislation | Trusts Ordinance 2016 (Chapter 16.12), text as at 31 March 2018The Turks and Caicos Islands: Trusts Ordinance, Chapter 16.12 (Revised Edition 2018) | Trust Act of 1994, Title 50, Chapter 1 of the Revised Code (2004 edition)Marshall Islands Revised Code: Trust Act (1994), 50 MIRC Chapter 1 (FAOLEX copy) | Trusts Act (Cap. 5.19), with 2018 and 2019 amending ActsFSRC St Kitts: Trusts law library | Trust Act, with related Acts listed by the FSASVG FSA: Trusts |
| Legal basis | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | Trust (Treuhänderschaft) provisions start at Art. 897 of the PGRLiechtenstein Law Gazette: Persons and Companies Act (PGR) | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – |
| Perpetuity period | Settlors may set up perpetual trusts from 1 December 2013Hong Kong Government press release: Trust Law (Amendment) Ordinance 2013 gazetted (26 July 2013) | 100 years, or a shorter period set in the instrument (Civil Law Act, section 32)Singapore Statutes Online: Civil Law Act 1909 | – | A Jersey trust may last for an unlimited period (Article 15)Jersey Law Website: Trusts (Jersey) Law 1984 | A DIFC trust may continue indefinitely; no perpetuity rule appliesTrust Law 2018, Dubai International Financial Centre (consolidated March 2024) | Trusts made after Aug 2024 may disapply the perpetuity rule; STAR trusts unaffectedOgier: Adapting to Cayman Islands perpetuities changes (2025) | No set limit on how long a Guernsey trust lasts, subject to its terms (s. 16)States of Guernsey: Billet d'Etat XIX 2007, Projet de Loi, The Trusts (Guernsey) Law, 2007 | – | No rule against perpetuities; unlimited duration unless the deed says otherwiseNevis FSRC: Trusts | – | – | – | Perpetuities and Accumulations Act 2009: no perpetuity period for new trustsBermuda Laws Online: Perpetuities and Accumulations Act (2009) | Perpetuity period is 125 years (Trusts Act 2019)New Zealand Legislation: Trusts Act 2019 | A trust other than a purpose trust may last up to 99 years (s. 9)Attorney General's Office: Trusts Act (Act 14 of 2001), Revised Laws of Mauritius | – | No fixed maximum duration under the Law as amended in 2012CyLaw: International Trusts Law (1992) | SDCL 43-5-8: the common-law rule against perpetuities is not in forceSouth Dakota Legislature: SDCL 43-5-8, Rule against perpetuities not in force | NRS 111.1031: nonvested interests are valid if they vest within 365 yearsNevada Legislature: NRS Chapter 111, Estates in property; conveyancing and recording | No limit on personal property in trust; real property after 110 yearsDelaware Code: Title 25, chapter 5, Rule Against Perpetuities | Non-real property can stay in trust for up to 1,000 yearsWyoming Statutes: Title 34, Property, Conveyances and Security Transactions | Powers of appointment must be exercised or end within 1,000 yearsAlaska Statutes: Title 34, chapter 27, Statutory Rule Against Perpetuities | The instrument can exclude the rule against perpetuities, on conditionsNew Hampshire Revised Statutes: Exemption from the Rule Against Perpetuities | Trusts may last up to 360 yearsChambers: Tennessee Trust Bill Takes Effect and Makes Important Changes to the State's Trust Laws | Unlimited duration unless the trust terms fix one (section 16)Laws of Malaysia: Labuan Trusts Act 1996 (Act 554) | 2011 reforms include the Rule Against Perpetuities (Abolition) ActBahamas Financial Services Board via Legal 500: The Bahamas Toolkit (2025) | Maximum 120 years from creation (s.6(1)), except charitable trustsFinancial Services Commission Belize: Trusts Act, Chapter 202 (Revised Edition 2020) | Maximum duration 125 years (Art. 12)Malta Ministry for Justice: Trusts and Trustees Act (Cap. 331) | – | – | The Perpetuities and Accumulations Act 1986 was amended in 2014Laws of Gibraltar: Perpetuities and Accumulations legislation | – | A Seychelles trust may continue indefinitely; no perpetuity rule applies (s. 15)Official Gazette: Trusts Act 2021 (Act 34 of 2021) | – | – | – | Trusts can be perpetual rather than time-limitedVisit TCI, Financial Services: Trusts | Section 108 (2004 text): up to 100 years, charitable trusts exceptedMarshall Islands Revised Code: Trust Act (1994), 50 MIRC Chapter 1 (FAOLEX copy) | – | – |
| Protector | – | – | – | – | – | STAR trust: a beneficiary cannot enforce it; the enforcer can (s.100)Walkers: Cayman Islands STAR Trusts, Reinforcing the Role of Enforcers (2024) | – | – | – | – | – | – | STAR trust: a beneficiary cannot enforce it; the enforcer can (s.100)Walkers: Cayman Islands STAR Trusts, Reinforcing the Role of Enforcers (2024) | – | The deed may create a protector, who may be the settlor (s. 24)Attorney General's Office: Trusts Act (Act 14 of 2001), Revised Laws of Mauritius | – | – | SDCL 55-1B-1: defines trust protector and trust advisorSouth Dakota Legislature: SDCL 55-1B-1, Definition of terms | NRS 163.5547: defines the trust protectorNevada Legislature: NRS Chapter 163, Trusts | The deed can name advisers and protectors with defined powersDelaware Code: Title 12, chapter 33, Administrative Provisions | The deed can name a trust protector and a trust advisorWyoming Statutes: Title 4, chapter 10, Uniform Trust Code | – | The trust code provides for trust advisors and trust protectorsNew Hampshire Revised Statutes: Powers of Trust Advisors and Trust Protectors | – | – | – | – | Settlor may reserve the power to appoint a protector (Art. 14A)Malta Ministry for Justice: Trusts and Trustees Act (Cap. 331) | – | – | – | – | – | – | – | – | – | – | – | A protector cannot also be the trustee of the same trustSVG FSA: Trusts |
| Asset protection rule | – | – | – | – | – | – | – | 1989 Act: bankruptcy (13A), fraud (13B), foreign judgments (13D), spendthrift (13F)International Trusts Amendment Act 1989 (No. 23), FSC copy | A creditor's sole remedy is a claim of fraudulent transferNevis FSRC: Trusts | – | – | – | – | – | – | – | – | SDCL 55-16-10: creditor claims are time-limited; clear and convincing proofSouth Dakota Legislature: SDCL 55-16-10, Claim of fraudulent transfer of settlor's assets | NRS 166.170: creditor challenges are time-limited; clear and convincing proofNevada Legislature: NRS Chapter 166, Spendthrift trusts | A creditor must prove its case by clear and convincing evidenceDelaware Code: Title 12, chapter 35, subchapter VI, Qualified Dispositions in Trust | Creditor claims must follow the Uniform Fraudulent Transfer ActWyoming Statutes: Title 4, chapter 10, Uniform Trust Code | A creditor must prove intent to defraud by clear and convincing evidenceAlaska Statutes: Title 34, chapter 40, Restricting Transfers of Trust Interests | A creditor must prove the transfer was fraudulent as to that creditorNew Hampshire Revised Statutes: Creditor's Claim Against a Settlor of an Irrevocable Trust | A creditor must prove intent to defraud by clear and convincing evidenceTennessee Code: Tennessee Investment Services Act of 2007, chapter 16 | – | Fraudulent Dispositions Act 1991: two-year limitation for asset protection trustsBahamas Financial Services Board via Legal 500: The Bahamas Toolkit (2025) | – | – | – | – | – | – | – | – | – | – | – | Section 145: a creditor must prove principal intent to defraudMarshall Islands Revised Code: Trust Act (1994), 50 MIRC Chapter 1 (FAOLEX copy) | Provisions cover settlor transfers, retained control, bankruptcy and fraudFSRC St Kitts: Asset Protection Provisions | – |
| Foreign law rules | The government said home-country forced heirship rules are not meant to influence how trust assets are allocatedHong Kong Government press release: Trust Law (Amendment) Ordinance 2013 gazetted (26 July 2013) | Foreign forced heirship rules do not defeat certain trusts (section 90)Singapore Statutes Online: Trustees Act 1967, section 90 | – | – | In DIFC, foreign heirship rights are not recognised for trusts (Art. 15)Trust Law 2018, Dubai International Financial Centre (consolidated March 2024) | – | Validity of a Guernsey trust follows Guernsey law, not other law (s. 14)States of Guernsey: Billet d'Etat XIX 2007, Projet de Loi, The Trusts (Guernsey) Law, 2007 | – | – | The Hague Trusts Convention entered into force for Switzerland on 1 July 2007HCCH: Trusts Convention status table | A Manx trust is not void just because it defeats foreign heirship rightsIsle of Man Government: Trusts Act 1995 (as enacted) | A Panama trust may be run under foreign law if the deed says so (art. 38)Organo Judicial (CENDOJ): Ley 1 de 1984 sobre fideicomiso (Gaceta Oficial 19971) | – | – | A foreign inheritance rule cannot undo a non-citizen's transfer to a trust (s. 8)Attorney General's Office: Trusts Act (Act 14 of 2001), Revised Laws of Mauritius | – | – | SDCL 55-3-49: no outside judgment enforced until a state court confirms fitSouth Dakota Legislature: SDCL 55-3-49, Enforcement of foreign judgments | – | Forced heirship, legitime and elective share claims are not exception claimsDelaware Code: Title 12, chapter 35, subchapter VI, Qualified Dispositions in Trust | Forced heirship and legitime claims cannot be raised against the trustWyoming Statutes: Title 4, chapter 10, Uniform Trust Code | – | Forced heirship and similar rights do not reach the settlor's interestNew Hampshire Revised Statutes: Creditor's Claim Against a Settlor of an Irrevocable Trust | Forced heirship, legitime and elective share claims are not exceptionsTennessee Code: Tennessee Investment Services Act of 2007, chapter 16 | Foreign succession claims, incl. fixed shares, are not recognised (section 10)Laws of Malaysia: Labuan Trusts Act 1996 (Act 554) | – | s.7(6): limits on foreign heirship, marital and insolvency claimsFinancial Services Commission Belize: Trusts Act, Chapter 202 (Revised Edition 2020) | – | – | Convention in force for the Netherlands since 1 February 1996HCCH: Convention on the Law Applicable to Trusts and on their Recognition (1985) | The 1989 Act deals with recognising foreign trustsLaws of Gibraltar: Trusts legislation | – | Questions on a Seychelles trust are decided by Seychelles law (s. 66)Official Gazette: Trusts Act 2021 (Act 34 of 2021) | – | – | – | – | – | – | – |
| Reserved settlor powers | Settlor may reserve investment powers without the trust failingTrustee Ordinance (Cap. 29), Hong Kong e-Legislation | Settlor may keep investment powers without the trust failing (section 90)Singapore Statutes Online: Trustees Act 1967, section 90 | – | Reserved powers such as directing investments do not affect validity (Article 9A)Jersey Law Website: Trusts (Jersey) Law 1984 | In DIFC, a settlor may reserve powers to revoke or vary a trust (Art. 84)Trust Law 2018, Dubai International Financial Centre (consolidated March 2024) | – | Reserving powers, such as to revoke or vary, does not void the trust (s. 15)States of Guernsey: Billet d'Etat XIX 2007, Projet de Loi, The Trusts (Guernsey) Law, 2007 | 1989 Act section 13C is headed retention of control and benefitsInternational Trusts Amendment Act 1989 (No. 23), FSC copy | – | – | – | A Panama trust is irrevocable unless the deed expressly says otherwise (art. 7)Organo Judicial (CENDOJ): Ley 1 de 1984 sobre fideicomiso (Gaceta Oficial 19971) | Trusts (Special Provisions) Act 1989: reserved powers added by 2014 amendmentBermuda Laws Online: Trusts (Special Provisions) Act (1989) | – | – | – | – | SDCL 55-16-2: irrevocable trust; settlor may keep listed powers and interestsSouth Dakota Legislature: SDCL 55-16-2, Trust instrument defined | NRS 166.045: the settlor has only the powers the trust instrument givesNevada Legislature: NRS Chapter 166, Spendthrift trusts | The transferor may keep a distribution veto and a power to remove trusteesDelaware Code: Title 12, chapter 35, subchapter VI, Qualified Dispositions in Trust | The settlor may keep a distribution veto and act as investment advisorWyoming Statutes: Title 4, chapter 10, Uniform Trust Code | The settlor may appoint and remove trustees, protectors and advisorsAlaska Statutes: Title 34, chapter 40, Restricting Transfers of Trust Interests | – | – | Settlor may keep powers such as revoking or directing the trustees (section 8B)Laws of Malaysia: Labuan Trusts Act 1996 (Act 554) | Settlors can exercise reserved powers under Bahamian lawBahamas Financial Services Board via Legal 500: The Bahamas Toolkit (2025) | – | – | – | – | – | – | A settlor may reserve powers such as revoking or varying the trust (s. 16)Official Gazette: Trusts Act 2021 (Act 34 of 2021) | – | – | – | – | – | – | – |
| Registration | – | – | Business Companies Act s.96A: exempts companies whose shares a qualifying trustee holdsMourant: Amendments to the BVI beneficial ownership regime in force (2025) | – | The Registrar's Register of DIFC foundations is open to inspection (Art. 35)Foundations Law 2018, Dubai International Financial Centre (consolidated March 2024) | – | – | 1984 Act provides an annual certificate of registrationAct No. 14 of 1984 (FSC copy) | Entered on the register of international trusts through a registered agentNevis FSRC: Trusts | – | – | – | – | Register in myIR with the trust deed, settlements and connected personsInland Revenue: Register a New Zealand foreign trust | – | – | – | – | – | – | – | – | A foundation is formed by a certificate filed with the Secretary of StateNew Hampshire Revised Statutes: New Hampshire Foundation Act | The Tennessee Code has a section on private trust companiesTennessee Code: Private Trust Companies, chapter 2 | A Labuan trust may be registered with the Authority (section 12)Laws of Malaysia: Labuan Trusts Act 1996 (Act 554) | Beneficial Ownership Act in force 20 December 2018; agents hold company dataTrident Trust: Beneficial Ownership Reporting Requirements in the Bahamas (2019) | Register of International Trusts, not public (ss.65A, 65C)Financial Services Commission Belize: Trusts Act, Chapter 202 (Revised Edition 2020) | – | – | – | – | Registration of a trust is optional under the Trusts ActAnguilla FSC: Trust sector page | An approved trustee registers a trustee appointment declaration (s. 11)Official Gazette: Trusts Act 2021 (Act 34 of 2021) | – | – | – | – | Part V: register by trustee certificate or copy of the trust instrumentMarshall Islands Revised Code: Trust Act (1994), 50 MIRC Chapter 1 (FAOLEX copy) | A trust is enforceable once the Registrar issues a certificateFSRC St Kitts: Creation and Establishment of Trusts | Application includes the trust deed or deed of settlementSVG FSA: Trusts |
| Registry search | – | – | – | – | – | – | – | Registrar may confirm name, date, number, office and administering trustee on requestFinancial Supervisory Commission, Registry | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – |
| International trust means | – | – | – | – | – | – | – | – | – | – | – | – | – | No New Zealand-resident settlor, or the foreign-sourced income exemption is usedInland Revenue: Foreign exemption trusts | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – |
| Trustee requirement | – | Trust business is restricted (section 3); exempt persons are listed (section 15)Singapore Statutes Online: Trust Companies Act 2005 | – | A Jersey trust must have at least one trustee (Article 16)Jersey Law Website: Trusts (Jersey) Law 1984 | – | – | – | As enacted, s.2 asks for a listed type of company as trustee or power holderAct No. 14 of 1984 (FSC copy) | A Nevis corporation or a trust company doing business in NevisNevis FSRC: Trusts | – | – | – | – | A New Zealand foreign trust must have one or more resident trusteesInland Revenue: Register a New Zealand foreign trust | A trust has up to four trustees; at least one must be a qualified trustee (s. 28)Attorney General's Office: Trusts Act (Act 14 of 2001), Revised Laws of Mauritius | – | – | SDCL 55-3-41: qualified trustee is a state resident, trust company or bankSouth Dakota Legislature: SDCL 55-3-41, Qualified person defined | NRS 166.015: a settlor-beneficiary trust needs a Nevada-based trusteeNevada Legislature: NRS Chapter 166, Spendthrift trusts | Qualified trustee: a Delaware-resident individual or a supervised entityDelaware Code: Title 12, chapter 35, subchapter VI, Qualified Dispositions in Trust | Qualified trustee: a Wyoming-resident individual or an authorised entityWyoming Statutes: Title 4, chapter 10, Uniform Trust Code | – | – | Qualified trustee: a Tennessee-resident individual or a supervised entityTennessee Code: qualified trustee and trust instrument, chapter 16 | A Labuan trust company must be one of the trustees (section 7)Laws of Malaysia: Labuan Trusts Act 1996 (Act 554) | – | International trust needs a trust agent in Belize (s.65E(1))Financial Services Commission Belize: Trusts Act, Chapter 202 (Revised Edition 2020) | – | Fiduciary in a fiducie must be a financial institution that the law listsLegilux: Law of 27 July 2003 on trusts and fiduciary contracts | – | – | The Commission's page describes local trust companiesAnguilla FSC: Trust sector page | Every trust must have an approved trustee; co-trustees may live abroad (s. 21)Official Gazette: Trusts Act 2021 (Act 34 of 2021) | The Trustee Companies Act 2017 governs trustee companiesPacLII: Trustee Companies Act 2017 (Samoa) | The Trust Companies Act (Cap. 69) is the trust company statute of VanuatuPacLII: Trust Companies Act (Cap. 69) (Vanuatu) | Trustee defined by reference to two named ActsParliament of Barbados: Trusts (Miscellaneous Provisions) Bill 2018 | – | – | At least one trustee who ordinarily resides in the FederationFSRC St Kitts: Creation and Establishment of Trusts | Applications go through a trustee that the authority recognisesSVG FSA: Trusts |
| Reporting to authorities | Reporting financial institutions existing before 2027 and not yet registered must register by 31 March 2027Inland Revenue Department: Inland Revenue (Amendment) (Automatic Exchange of Information) Ordinance 2026 | Singapore has exchanged account information under the CRS since September 2018Inland Revenue Authority of Singapore: CRS overview and latest developments | Existing entities: BO rules from 1 Jan 2026; access requests from 1 Apr 2026Mourant: Amendments to the BVI beneficial ownership regime in force (2025) | Jersey signed the CRS competent authority agreement on 29 October 2014Government of Jersey: Common Reporting Standard (CRS) | The UAE takes part in FATCA and the Common Reporting StandardUAE Ministry of Finance: Automatic exchange of information (FATCA and CRS) | – | Guernsey takes part in automatic exchange of tax information under the CRSStates of Guernsey: Common reporting standard (CRS) | 2016 Amendment Act brought in the Common Reporting StandardMinistry of Finance and Economic Management, Legislation and Reporting: Income Tax (Automatic Exchange of Financial Account Information and Other Matters) Amendment Act 2016 | – | The Swiss legal basis for automatic exchange of financial account information took effect on 1 January 2017State Secretariat for International Finance: Automatic exchange of information | The Isle of Man takes part in automatic exchange of tax information under the CRSIsle of Man Government: Income Tax Division information | – | – | Contact trustee must register and meet disclosure and annual return dutiesInland Revenue: Foreign exemption trusts | The Revenue Authority publishes CRS and FATCA registration and reporting guidanceMauritius Revenue Authority: Common Reporting Standard (CRS) | – | – | Form 706-NA may be due on US-situated assets of a nonresident non-citizenIRS: Some nonresidents with U.S. assets must file estate tax returns | Form 706-NA may be due on US-situated assets of a nonresident non-citizenIRS: Some nonresidents with U.S. assets must file estate tax returns | A nonresident non-citizen's estate files Form 706-NA above a US-asset thresholdInternal Revenue Service: Some nonresidents with U.S. assets must file estate tax returns | A nonresident non-citizen's estate files Form 706-NA above a US-asset thresholdInternal Revenue Service: Some nonresidents with U.S. assets must file estate tax returns | A nonresident non-citizen's estate files Form 706-NA above a US-asset thresholdInternal Revenue Service: Some nonresidents with U.S. assets must file estate tax returns | A nonresident non-citizen's estate files Form 706-NA above a US-asset thresholdInternal Revenue Service: Some nonresidents with U.S. assets must file estate tax returns | A nonresident non-citizen's estate files Form 706-NA above a US-asset thresholdInternal Revenue Service: Some nonresidents with U.S. assets must file estate tax returns | – | – | CRS (Common Reporting Standard): agreement signed 29 October 2015; FATCA not mentioned on that pageFinancial Services Commission Belize: Automatic Exchange of Information | – | – | – | – | – | Seychelles committed to the first Common Reporting Standard (CRS) exchange, 2017Seychelles Revenue Commission: International Tax | – | Global Forum review (April 2026): Vanuatu rated largely compliantKPMG: ETF 585, update of the EU list of non-cooperative jurisdictions (October 2026) | – | – | – | – | – |
| Trustee remuneration | Pay follows the deed; if the deed is silent, the Trustee Ordinance lets a professional trustee charge reasonable payTrustee Ordinance (Cap. 29), Hong Kong e-Legislation | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – |
| Stamp duty on transfers | Stamp duty can arise when Hong Kong shares or Hong Kong property move into a trustStamp Duty Ordinance (Cap. 117), Hong Kong e-Legislation | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – |
| Estate duty | Hong Kong abolished estate duty for deaths on or after 11 February 2006Inland Revenue Department: Estate duty | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | The state has no state income tax or estate tax on individualsSouth Dakota Department of Revenue: Individual taxes | Nevada does not require estate tax filing for deaths on or after 2005Nevada Department of Taxation: Estate Tax FAQs | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – |
| Fee rules | – | – | – | – | – | – | – | Government fees: regulations made under the International Trusts Act 1984Financial Supervisory Commission, Legislation and Regulations | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – | – |
This is guidance, not legal or tax advice. Each fact names its source; we read the sources on and .
How to use this comparison
Tick up to 4 places in the picker to build a trust jurisdiction comparison. The table lists every fact we hold for them, one column per place. Cells that differ are shaded and announced to screen readers.
Rows we have not published for a place are listed below the table, with one Ask us link to send the question. We never fill a gap with a guess.
Trust versus foundation
The difference is who or what holds the assets. In a trust, a trustee holds them under a deed for the beneficiaries. In a foundation, the foundation itself holds them, and a council runs it under its charter.
Some places in the table offer foundations as well as trusts; open a place page to see which structures we describe there. Many families choose by the legal system they know: a trust fits common-law habits, a foundation fits civil-law habits.
Neither structure is better in itself. The choice follows from where the family lives, which structure the chosen place recognises and what the family wants the trustee or council to decide.
Domestic versus offshore trust
A domestic trust is governed by the law of the place where the settlor lives. An offshore trust is governed by the law of another place, with a trustee there.
The choice between domestic vs offshore trusts affects which court hears a dispute, which reporting rules apply to the trustee and how the home country treats the structure. The last point is a question for your tax adviser, not for this page.
Compare any two of the 40 places
The picker lists all 40 places in catalogue order. For two places at a time, open one of the pair pages listed under Comparisons to start with.
What the comparison does not tell you
It shows only facts that have a source, each with that source and the date it was read. It does not rank places, predict a legal or tax result or replace advice from your own lawyer. A fact that is missing here may matter to you, so ask us before you rely on a gap.
Catalogue
All 40 places we cover
Asia Pacific
Americas and Caribbean
- BVIGuide published
- Cayman IslandsGuide published
- NevisGuide published
- PanamaGuide published
- BermudaGuide published
- South Dakota (USA)Guide published
- Nevada (USA)Guide published
- Delaware (USA)Guide published
- Wyoming (USA)Guide published
- Alaska (USA)Guide published
- New Hampshire (USA)Guide published
- Tennessee (USA)Guide published
- BahamasGuide published
- BelizeGuide published
- AnguillaGuide published
- BarbadosGuide published
- Turks and CaicosGuide published
- St KittsGuide published
- St Vincent and the GrenadinesGuide published
Europe
Middle East and Africa
No jurisdiction matches "". Try a country or region name.
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Two places
Comparisons to start with
- Hong Kong vs Singapore
- Cook Islands vs Nevis
- BVI vs Cayman Islands
- Jersey vs Guernsey
- Hong Kong vs BVI
- Singapore vs New Zealand
- South Dakota vs Nevada
- Delaware vs Wyoming
- Cook Islands vs Belize
- Cayman Islands vs Bermuda
- Jersey vs Isle of Man
- Switzerland vs Liechtenstein
- UAE vs Mauritius
- Labuan vs Singapore
- Hong Kong vs Jersey
- Nevis vs Belize
- Alaska vs South Dakota
- Malta vs Cyprus
- Luxembourg vs Netherlands
- Seychelles vs Mauritius
FAQ
Questions about trusts, foundations and places
What is the difference between a trust and a foundation?
One is a duty, the other is a legal person. A trust binds a trustee to look after assets for others, while a foundation exists in its own right and is run by a council. Families weighing a family foundation vs trust should start with the places they are considering, because not every place offers both. Your lawyers confirm the rest.
Which trust jurisdiction is best?
Lists of the best trust jurisdictions rank places, but none is best for every family. The right place depends on where you live, what the trust will hold, who benefits and how much say you want. Use the picker to put places side by side, take the finder for a shortlist and ask your own advisers to test the shortlist against your circumstances.
Can a structure combine a trust and a foundation?
Some families do. A typical pattern is a trust that owns the shares of a company, or a foundation that sits above a holding company. Whether the laws of the places involved allow a combination is a question for your lawyers. We administer the structure the lawyers design.
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