Technical article

The United Arab Emirates and Singapore: Nothing to Pay, and What Your Old Country Still Wants

A person counts as resident with 183 days or more in the calendar year before the year of assessment.

By Neil Solomon · 3 min read

Imagine a family where a father in the United States has a trust for his son, and the son is looking at Dubai or Singapore. Both have a name for taxing little. The father asks two things: does the new country tax a trust payment, and does the old one stop?

The United Arab Emirates. PwC, tier B, says there is no personal income tax at federal or emirate level. Foreign income is not taxed. Trust income and trust principal received by a resident are not taxed. There is no inheritance, estate or gift tax on individuals. A person counts as resident under any one of three tests. One is 183 days or more in a consecutive 12-month period. Another is a usual or primary residence plus a centre of financial and personal interests there.

Singapore. PwC says foreign-sourced income received by an individual in Singapore is not taxed, unless it comes through a Singapore partnership. A legal source cites section 13(7A) of the Income Tax Act for this. A trustee's firm (the Sovereign Group, tier C) says exempt income received by a trust beneficiary is exempt too, though it writes about Singapore trusts and not capital payouts. Estate duty was abolished for deaths from 15 February 2008, and PwC mentions no gift or inheritance tax. A person counts as resident with 183 days or more in the calendar year before the year of assessment. The top rate for residents is 24% over SGD 1 million. Exempt income is still exchanged with other countries under the common reporting system, which PwC notes.

That covers the new country. The old one is a separate question, and it depends on which old country.

The sources for the United States are plain. A US citizen heir living abroad is taxed on a distribution from a US trust like any US person. The IRS says a domestic trust passes its income to the heir on a Schedule K-1, and the character of the income is kept. The heir's own foreign accounts may need reports too: the foreign-bank-account report applies above US$10,000 in total, and a second form, 8938, at US$200,000 at year end for a single person living abroad. Giving up US citizenship brings an exit tax, as if all property had been sold the day before, with a base exclusion of US$600,000 that is adjusted for inflation. These are tier A.

The UK works differently. The sources say that from 6 April 2025 UK inheritance tax follows a long-term residence test: UK-resident for 10 of the last 20 tax years. After leaving, a long-term resident stays in the inheritance net for 3 to 10 years, depending on the years of residence. That is the UK tax authority's own manual, tier A.

You might say: "If the new country charges nothing, I am done." The tables show only half the story. A person who keeps US citizenship keeps the US filings. A person who has been a long-term UK resident keeps a UK tail on inheritance tax. For both, the old country keeps its claim until residence there ends, or the tail runs out.

You could write down which old-country duties your heir still has: the return, the account reports, and any tail years. You could also ask the trustee how it treats a beneficiary who has moved, since the trustee holds the first record.

Family matters here. A son who moves and a daughter who stays in the United States may face two different sets of papers from the same trust.

If you or someone close has moved to the Emirates or Singapore, what did your old country still ask for? Share it here. Another family may be reading the same two lists.

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