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Technical article

Nevis, Belize and Panama: Tax Exemption Written into the Statute

Nevis and Belize look at the people: where the settlor and beneficiaries live, and whether the trust owns land.

Imagine a family reading three trust brochures. Each says the trust pays no tax. They want to see whether the law itself says so.

For Nevis, Belize and Panama, the sources show the law itself. Each exemption has conditions, and the conditions are where the family may look closely.

Place Where it is written What is exempt Conditions
Nevis International Exempt Trust Ordinance, section 49 Income tax; estate, inheritance, succession and gift tax; stamp duty Non-resident settlor and beneficiaries at all times; no Nevis land; a Nevis company, limited liability company, licensed or registered-agent trustee
Belize Trusts Act, Cap. 202, section 65D Income and Business Tax Act; death taxes; stamp duty Non-resident settlor and all beneficiaries; no Belize land; Belize law governs the trust
Panama Law 1 of 1984, article 35 Forming, changing, ending or transferring the trust, and its income Trust holds foreign assets, non-Panama-source money or shares of non-Panama-source companies

Nevis. Section 49 also exempts the trust from exchange controls. The conditions come from the ordinance's own definitions, as revised to 31 December 2017. A trust is registered through a registered office or agent. Registration costs US$300 and renewal is US$300 a year. The sources are the commission's own texts (tier A).

Belize. Section 65D covers a registered international trust. Registration is compulsory and goes through a trust agent. An unregistered one is invalid and unenforceable. The register is confidential, and the registrar can refuse or cancel a registration. The trustee is treated as a non-resident for exchange control. The text is the 2020 revised edition. A 2007 fee order shows a registration fee of US$100 and no annual fee, so a current schedule may differ.

Panama. Article 35 reaches the formation, change, ending and transfer of a trust and its income. The conditions concern the assets, and not the people. Assets inside Panama are not covered. The trustee pays separately any tax on trust assets, under article 15. Trust business is licensed and supervised by the banking regulator, now called the Superintendency of Banks.

Notice the difference in what the law asks. Nevis and Belize look at the people: where the settlor and beneficiaries live, and whether the trust owns land. Panama looks at the assets: whether they are foreign.

What the exemptions do not remove. All three places report under the account-information exchange system. Nevis follows the US reporting agreement of type one, in force 28 April 2016, and exchanged first by September 2018. Panama signed on 15 January 2018 and has the same type of US agreement, in force 25 October 2016. Belize signed on 29 October 2015, with a first exchange by September 2018. These details come from official exchange tables, tier A.

You might say: "If the statute exempts the trust, there is nothing left to think about." The statute covers the place's own taxes. The settlor's home country and the heirs' country have their own rules, and the exchange system means they may receive account details. The statute and the home rules are two separate questions.

You could keep a short checklist for any statute-based exemption: the section, who must be non-resident, where assets must be, whether a local trustee or agent is needed, and when the text was last revised. The list touches the settlor, whose residence is a condition, the trustee or agent, and the papers that prove each fact.

When you read a brochure's claim of no tax, did you go to the law itself? Share what you found here. Someone checking the same claim may be glad of your reading.

Figures are estimates for planning, based on public data. Date read: October 2026.

Sources

  • Nevis Financial Services Regulatory Commission, International Exempt Trust Ordinance, revised to 2017, and fee order of 2024 (A)
  • Belize Financial Services Commission, Trusts Act Cap. 202, 2020 revision (A)
  • Belize Statutory Instrument 68 of 2007 (A)
  • Superintendency of Banks of Panama, Law 1 of 1984 (A)
  • OECD, automatic exchange of information status (A)
  • US Treasury, FATCA agreements (A)

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