An offshore trust starts with a deed: the settlor transfers assets to a trustee, who holds them for the beneficiaries under the law the deed chooses. That law decides how long the trust may last, whether it has to be registered and what a creditor or a foreign court can still do about it. Below are 12 jurisdictions with their rules and official fees, the eight things a settlor decides and the six steps to a registered trust.
Updated · Reviewed by the Prifinance team
A trust is not a company. The settlor transfers assets to a trustee, who holds them in its own name for the beneficiaries or for a purpose, on the terms of the deed. Liechtenstein's PGR describes the trustee as an independent holder of rights over the trust property, with effect against everyone (art. 897).
The type decides how much the trustee chooses and who can make it keep to the terms.
The law licenses the trustee, not the trust. Cyprus, Malta, Liechtenstein and New Zealand also record the trust or its beneficial owners with an authority, each with its own deadline.
| Jurisdiction (regulator) | Who may act as trustee | Registration, registers and official fees |
|---|---|---|
| Jersey (JFSC)More details → | Trusteeship by way of business is trust company business, registered with the JFSC. A private trust company run by a registered firm for specific trusts is exempt once notified. | No registration of the trust under the Trusts Law. JFSC fees for 2026: £2,294 to apply, £1,053 for an individual with one class. |
| Guernsey (GFSC)More details → | A GFSC fiduciary licence for anyone paid to act as trustee or protector; a private trust company may hold a limited permission instead, generally for 3 years. Two trustees by default, but one is enough if only one was appointed, a Guernsey-resident corporate trustee acts or the deed allows it. | No registration of the trust under the 2007 Law. GFSC fees from 1 January 2026: £3,205 to apply for a primary licence (then from £7,110 a year, by turnover), £1,410 for a personal one (£1,460 a year), £1,475 for a company's limited permission. |
| Cyprus (CySEC, Cyprus Bar Association, ICPAC)More details → | A CySEC-licensed administrative service provider, or a lawyer or accountant supervised by the Cyprus Bar Association or ICPAC; one trustee must be resident in Cyprus at all times. | Register of Trusts kept by the trustee's supervisor: notice within 15 days of creation and of a change of name, trustees or governing law, no public access. CySEC also keeps CyTBOR for beneficial owners. |
| British Virgin Islands (FSC)More details → | An FSC trust licence for trust business. A private trust company doing only unremunerated or related business is exempt if its registered agent holds a Class I licence. | Trust deeds are not registered; US$200 of trust duty is stamped within 3 months. The trustee keeps beneficial ownership data and updates it within 30 days. Class I licence: US$1,200 to apply, US$19,200 a year. |
| New Zealand (Inland Revenue)More details → | No trustee licence in the Trusts Act 2019; professional trust service providers are reporting entities under the AML/CFT Act 2009. A sole trustee cannot be the sole beneficiary. | Registration with Inland Revenue (IRD) within 30 days from the due date of the trust's income tax return for the first income year in which it qualifies as a foreign exemption trust; NZ$270 to register and NZ$50 for each yearly return, or no fees if every trustee is an individual and not a professional trustee. |
| Liechtenstein (FMA, Office of Justice)More details → | Anyone may be trustee, but trusteeship by way of business needs an FMA licence under the Trustee Act (TrHG). If no trustee lives or has its seat in Liechtenstein, a representative is appointed. | Commercial register entry, or deposit of a certified copy of the deed with the Office of Justice, within 30 days for a trust of more than 12 months; CHF 300 either way. |
| Malta (MFSA)More details → | MFSA authorisation for paid or habitual trustees; a corporate trustee needs 3 approved directors and €15,000 of capital. A relative may act unpaid as a private trustee, and a family trust company registers. | Beneficial owners declared to the MFSA within 14 days and confirmed by 31 January each year; tax registration within 30 days. Fees for 2026: €2,500 to apply, then €5,500 plus €2,500 a year. |
The fees are the regulators' own figures, for 2026 where a year is given. What the trustee charges for running the trust is agreed in its engagement terms.
Country by country: fund vehicles and regulators, trusts and foundations.
Fund vehicle and manager, where to domicile the fund, who you need around it, capital, timelines and official fees by country.
What a private foundation does that a trust cannot, and the other way round, with the foundation laws of 14 jurisdictions compared.
Trustee discretion, letters of wishes, beneficiaries’ rights, settlor powers and the tax position by jurisdiction.
Five regimes that answer the same three questions in different ways: what a creditor must prove and by when, what happens to a foreign judgment, and how the trust is registered. Each of the five has its own page with the formation procedure.
| Jurisdiction and law | Creditor challenge: proof and time limit | Foreign judgments, heirship, registration and fee |
|---|---|---|
| Cook Islands - International Trusts Act 1984More details → | Proof beyond reasonable doubt of a principal intent to defraud and of insolvency caused by the transfer. A transfer is never fraudulent against a creditor whose claim arose after it, or more than 2 years before it; otherwise the creditor must sue on the claim within a year of the transfer and sue the trust in the Cook Islands High Court within 2 years. | Foreign judgments based on law inconsistent with the Act are not enforced; heirship claims do not invalidate the trust. Registered within 45 days of the trustee's appointment: US$310, and US$310 for each renewal of up to 5 years. |
| Nevis - Nevis International Exempt Trust OrdinanceMore details → | Proof beyond reasonable doubt of a principal intent to defraud. A transfer is not fraudulent against a creditor whose claim arose after it, or more than a year before it; actions within 2 years of the transfer, after an EC$270,000 bond from a Nevis financial institution. | No enforcement of foreign judgments based on law inconsistent with the Ordinance, and heirship claims are excluded. US$300 to register plus US$20 for the certificate, US$300 a year; the register is closed. |
| Cayman Islands - Trusts Act (2021 Revision), Fraudulent Dispositions ActMore details → | Voidable only if made with intent to defraud and at an undervalue, at the instance of a prejudiced creditor, who proves the intent and must sue within 6 years. | Foreign judgments conflicting with ss 91-92 on heirship and foreign law are not recognised. Ordinary trusts are not registered; an exempted trust pays CI$500 to register and CI$500 each March. |
| Belize - Trusts Act (Cap. 202), amended in 2023More details → | The court will not vary or set aside a Belize trust, or recognise foreign-law claims or foreign orders, over creditors' claims in an insolvency; an international trust has this protection only once registered. | The same applies to foreign marital and succession claims. Registration within 90 days, US$100; an unregistered international trust is invalid. Beneficial owners reported by 31 March each year. |
| Singapore - Trustees Act 1967, Trust Companies Act 2005More details → | A settlement on trust at an undervalue stays subject to s. 438 of the Insolvency, Restructuring and Dissolution Act 2018 (Trustees Act s. 86). | Inheritance rules do not affect a Singapore-law trust with resident trustees and a settlor who is neither a citizen nor domiciled in Singapore (s. 90). No trust register; a licensed trust company pays SGD 1,000 to apply and SGD 4,000 a year. |
Eight decisions and documents. Each one is a condition somewhere among the 12 jurisdictions on this page, and the trustee will ask for most of them before it accepts the trust.
The trust laws, fee schedules and regulator pages behind each figure on this page.
Laws, fees and deadlines as in force on 4 November 2026. Where a legislature or a regulator changes a figure, the text linked here prevails.
What the trust must achieve, who is in the family, where the settlor and the beneficiaries live and pay tax, which assets go in. We answer in writing with the jurisdiction and the type of trust we recommend.
Governing law first, then the type: discretionary, fixed interest, purpose, protective or VISTA. The residence tests of Cyprus, New Zealand and the Cook Islands are checked here, before any drafting.
A licensed trustee reviews the settlor and the assets and agrees to act. The protector, any enforcer and, in Liechtenstein, the person entitled to information are chosen at the same stage.
We draft the trust deed: beneficiaries, distribution powers, powers kept by the settlor, the protector, governing law and forum. The letter of wishes is written and signed separately.
The deed is signed and the assets move to the trustee: shares re-registered, accounts opened in the trustee's name, the BVI duty stamp affixed within 3 months.
Filings within the deadlines on this page, then the yearly round: the MFSA confirmation by 31 January, the Belize report by 31 March, renewal every year in Nevis and at least every 5 years in the Cook Islands.
This market is full of intermediaries selling one product because it is the one they sell. We work both sides of the section. Regulated funds and private structures, which is why we can tell you that the thing you asked for is not the thing you need, and then build the one that is.
Fund lawyers and private-client lawyers in the same firm, so the answer to fund or trust is argued from your facts rather than from what we happen to sell.
Before you pay anyone, you get a written view of what the structure does, where its limits run, and what it will not protect you from.
The quote you approve is the price you pay. State, regulator, trustee, administrator and audit fees are stated separately and upfront.
Offering documents, fund rules and risk frameworks drafted to the regulator's standards; deeds, letters of wishes and beneficiary classes drafted for the family as it will become, not as it is today.
Renewals, annual returns, audited statements, TUBOR and IRD filings, trustee changes and restructuring. Including migrating a structure that has outgrown the one it started in.
15 years in FinTech and asset structuring. Decides with you whether the answer is a fund or a private structure, then maps it to a domicile and leads the file to the regulator's decision.
Builds the structure itself: the local vehicle, the AML/KYC policy pack, capital and service-provider contracts, fund documentation and tax registrations. His document sets are the reason reviews finish in months, not years.
First point of contact for international founders and families. Runs the whole set-up remotely, across time zones and languages - from the first call to a live fund or an executed deed.
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Usually a trust governed by the law of a country where the settlor does not live, with a trustee licensed there. The settlor transfers the assets; the trustee holds them in its own name for the beneficiaries. Jersey's Trusts Law puts the core in one line: the trustee holds property of which it is not the owner in its own right. Some laws add a category for foreign settlors. Cyprus has the international trust, New Zealand the foreign exemption trust.
Decide what the trust is for and where the beneficiaries live, then choose the governing law and a licensed trustee in that jurisdiction. The trustee checks you and the assets, the deed is drafted and signed, and the assets are transferred to the trustee. Registration follows where the law asks for it: within 15 days in Cyprus, 30 in Liechtenstein, 90 for a Belize international trust. The Jersey and Guernsey trust laws ask for none.
The state's share is small: US$100 to register in Belize, CHF 300 in Liechtenstein, US$310 in the Cook Islands, NZ$270 in New Zealand, US$200 of trust duty in the BVI, CI$500 for a Cayman exempted trust. Most of the cost is the trustee's yearly fee and the drafting, which depend on the assets and the structure. We fix our own fee in writing after a free assessment.
It depends on the risk you are planning for and where the assets are. The Cook Islands and Nevis put the heaviest burden on a creditor: intent to defraud proved beyond reasonable doubt, short time limits and, in Nevis, an EC$270,000 bond before any suit. Cayman needs both intent and an undervalue and allows 6 years. Jersey and Guernsey offer firewall rules against foreign judgments and heirship claims, and their courts keep the power to undo a fraud on creditors (Jersey art. 59, Guernsey s. 84).
Depends on the law. Cyprus, Malta, Liechtenstein and New Zealand record the trust or its beneficial owners with an authority; Belize, Nevis and the Cook Islands register international trusts, and an unregistered Belize international trust is invalid. The Jersey and Guernsey trust laws and the BVI Trustee Act create no register of trusts, though a BVI trustee must keep beneficial ownership information itself (s. 92B).
Belize allows anyone with capacity to own and transfer property, but a Belize international trust needs at least one trustee that is a Belize company or a licensed trust company, plus a licensed trust agent in Belize; Malta lets a relative of the settlor act unpaid as a private trustee. Professional trusteeship is licensed: JFSC registration in Jersey, a GFSC fiduciary licence in Guernsey, MFSA authorisation in Malta, an FMA licence in Liechtenstein, a MAS licence in Singapore. Some laws also want a local trustee: in Cyprus at least one resident trustee at all times, and for a New Zealand foreign exemption trust a trustee resident in New Zealand.
Within limits the laws spell out. Jersey, Guernsey, Cyprus and Cayman list powers a settlor may keep without invalidating the trust: to revoke or amend it, to direct investments, to appoint or remove trustees. A protector can hold consent and appointment powers instead. Liechtenstein draws the line at continuing instructions, which the deed may not impose on the trustee, and in Cyprus a power kept by the settlor as protector is no ground in itself to attribute intent to defraud.
The law sets only the filing clocks: 14 days from the trustee's appointment in Malta, 15 days from creation in Cyprus, 30 in Liechtenstein, 45 in the Cook Islands, 90 in Belize. Before that the trustee has to accept the trust, which it does after its own checks on the settlor and the assets. The Cook Islands regulator says a registration by a licensed trustee company typically takes less than 24 hours.
Each law answers differently, and the answer usually turns on where the beneficiaries live. Jersey and Guernsey do not tax trustees on foreign income when all beneficiaries are non-resident (Concession M1, Practice M12); Cyprus taxes non-resident beneficiaries only on Cyprus income; New Zealand exempts the foreign income of a registered foreign exemption trust; BVI trust income is exempt unless the trust holds BVI land or trades there. These are local positions, and the countries where the settlor and the beneficiaries live apply their own rules.
A company formed to be trustee of one family's trusts, not to serve the public. Jersey exempts it from registration when a registered trust company administers it and the JFSC is notified; Guernsey grants a limited permission, generally for 3 years; the BVI exempts it if its registered agent holds a Class I licence; Cayman registers it with CIMA for CI$3,500 and CI$4,000 a year. In Singapore it needs no licence but must engage a licensed trust company for anti-money laundering checks.
Tell us what the trust should achieve, who the beneficiaries are, where you and they live and which assets go in. Our lawyers reply in writing with the jurisdiction, the type of trust, the trustee options, the official fees and our fixed fee.
