Trust Formation & Asset Protection Comparison

Updated time: Mar 21, 2018 , 15:19 (UTC+08:00)
Original Source Law Common Law  
Registration with Registrar of Companies No Yes
Separate Legal Personality No Yes
Confidentiality Records not available for public Inspection Records not available for public inspection except when authorized by Secretary of Foundation or FSC*
Constitutive document Trust Deed Charter and Articles (if Any)
Secretary No Yes
Protector Yes, may be designated Yes, may be designated in the Charter
Tax Status Tax Exempt if non-resident Tax Exempt if non-resident
Re-Domiciliation Allowed by change of Trustee and proper law Allowed
Asset Ownership Vested in Trustee Owns assets directly
Management of assets By Trustee By Council and Officers
Duration Up to 99 years for Discretionary Trust Purpose Trusts may have a perpetual duration Perpetual unless otherwise provided in the Charter
Termination Maybe revocable or irrevocable Can be wound up by a unanimous resolution of its Council, whose members are

FSC*: Financial Services Commission.

Applicable of Comparison for Mauritius, Seychelles, Belize and BVI.