Technical article

Singapore, Hong Kong, Dubai and Switzerland: What a Trust Run There Pays

Four names come up: Singapore, Hong Kong, Dubai and Switzerland.

By Neil Solomon · 4 min read

Imagine a retired couple from Australia with a daughter in Portugal and a son in Canada. They want a trustee in a large financial centre. Four names come up: Singapore, Hong Kong, Dubai and Switzerland. They ask each trustee one thing. Will your country tax the trust when none of us live there?

The sources give a short answer for each. Most of what follows comes from one firm or one trustee page per place, so it reads as "this is how it is described" and not as a full rulebook.

Singapore

The Sovereign Group, a Singapore trustee (tier C, 2021), describes a route called the Qualifying Foreign Trust. It says the route exempts specified foreign income when a licensed Singapore trust company runs the trust and neither the settlor nor any beneficiary is a Singapore citizen or resident. The exempt income includes foreign interest, dividends, rent from foreign property and gains on designated investments. It also covers distributions to beneficiaries. The same trustee adds that the exemption can survive a later move to Singapore under conditions. The tax office (tier A) asks for estate and trust income on its Form T.

Hong Kong

Hong Kong taxes only income that comes from Hong Kong. A law firm in the 2026 Chambers guide (tier B) says a passive offshore investment trust will not ordinarily trigger Profits Tax. A trustee who runs a business for the trust can be taxed on those profits. The Hong Kong Trustees' Association (tier B) says the law treats a trustee as a taxable person for business profits. The same Chambers guide notes that Hong Kong companies, corporate trustees among them, that receive foreign passive income need substance, a participation exemption or a link to local activity to keep their exemption.

Dubai and the United Arab Emirates

A law firm article, Al Tamimi (tier B), says trusts are not subject to income tax in the United Arab Emirates. Where a trust is resident depends mainly on where the trustees live, and a trust resident in a taxable country can lose its Emirates treatment. The article was written for a 2021 guide and last updated in December 2022. The Emirates began its corporate tax in 2023, after that date.

Switzerland

Switzerland has no trust law of its own. It recognises foreign trusts under the Hague Convention on trusts, in force there from 1 July 2007. The Convention does not limit Swiss tax powers. A Swiss trustee firm, Dixcart (tier C, December 2021), says a Swiss-resident trustee is not liable to Swiss income or capital gains tax on assets it manages in a foreign trust. It says the settlor and beneficiaries are exempt while they are not Swiss residents.

The four at a glance

Three of the four rest on a trustee's or law firm's own page. That is how trust firms in these places describe their work, and it is a fair place to start. It is not the same as a tax office ruling.

You might say: "If the trustee wrote it, why trust it?" A trustee knows the daily rule and has every reason to state it correctly. A trustee also earns a fee from the sale. Both can be true. A fair way through is to ask for the rule in writing, with the section of law behind it.

You could ask each firm what happens if one heir moves to that country, who in the family receives the yearly statements, and which date the rule was last checked.

If you have compared trustees in different cities, what did one of them say that the others missed? Share it here. Someone else may be at the same table.

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