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Hong Kong vs Singapore: trust jurisdictions side by side
Hong Kong and Singapore are two of the 40 places we cover. Both are in Asia Pacific and open for new trusts with us. The table sets out the facts we hold for each place side by side, with the source and date of every fact.
The table
Facts side by side
Shaded cells differ between the two places.
Rows we have not published for a place are listed below the table.
| Fact |  Hong Kong |  Singapore |
|---|---|---|
| Governing law | Common law and the Trustee Ordinance (Cap. 29) | Trustees Act 1967: duty of care (Part 1A), investments (Part 2), powers (Part 3) |
| Perpetuity period | Settlors may set up perpetual trusts from 1 December 2013 | 100 years, or a shorter period set in the instrument (Civil Law Act, section 32) |
| Foreign law rules | The government said home-country forced heirship rules are not meant to influence how trust assets are allocated | Foreign forced heirship rules do not defeat certain trusts (section 90) |
| Reserved settlor powers | Settlor may reserve investment powers without the trust failing | Settlor may keep investment powers without the trust failing (section 90) |
Not published for Hong Kong: trustee requirement. Ask us.
Not published for Singapore: trustee remuneration, stamp duty on transfers and estate duty. Ask us.
This is guidance, not legal or tax advice. Every fact has a source, listed under Sources with its date.
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Read each place in full
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Sources
Read on :
- Trustee Ordinance (Cap. 29), Hong Kong e-Legislation. Used for governing law, reserved settlor powers.
- Singapore Statutes Online: Trustees Act 1967. Used for governing law.
- Hong Kong Government press release: Trust Law (Amendment) Ordinance 2013 gazetted (26 July 2013). Used for perpetuity period, foreign law rules.
- Civil Law Act 1909. Used for perpetuity period.
- Trustees Act 1967, section 90. Used for foreign law rules, reserved settlor powers.
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Our trust team takes you through the next step for either place.