The UK announced, on 29 May, that it had become the first G7 country to strike a trade deal with the Gulf Cooperation Council (GCC) after almost four years of negotiations. The Free Trade Agreement (FTA) opens unprecedented opportunities for businesses across the Gulf region, supporting economic diversification and the vision strategies driving the nations forward.

The GCC brings together six strategically important and high growth economies – Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the United Arab Emirates (UAE) – with a combined GDP of around £1.9 trillion and a population of over 62 million people.

The UK’s trade relationship with the GCC is already well established. Total bilateral trade stands at £53 billion annually, which is equivalent to the UK’s eighth largest export market for goods. The FTA provides a formal framework for that relationship for the first time and is expected to increase bilateral trade by £15.5 billion annually in the long term.

The FTA is designed to drive growth across key sectors including aerospace, agri-food, energy, technology and financial services, while promoting innovation through provisions covering artificial intelligence, paperless trade and clean energy.

It also supports small- and medium-sized enterprises (SMEs) through trade facilitation measures and digital tools. Strategically, the FTA strengthens the UK-GCC partnership, aligns with GCC economic transformation agendas, such as Vision 2030, and enhances investment flows.

Under the FTA, the GCC will progressively liberalise up to 90% of its tariff lines within 10 years of entry into force. The UK has agreed to eliminate tariffs on all current imports from the GCC as soon as the FTA is implemented, benefiting businesses exporting GCC goods to the UK. To benefit from preferential tariff rates, goods must comply with the FTA’s rules of origin.

Under streamlined customs procedures, businesses that meet certain defined criteria may benefit from reduced data requirements, lowering administrative burdens and costs. All goods are expected to be cleared for customs purposes within 48 hours, provided all requirements are met and no physical inspections are required. Perishable goods benefit from an accelerated clearance target of six hours.

The FTA supports the adoption of digital customs processes, which will simplify documentation, reduce processing times, and minimise costs for traders. Relevant customs information will be required to be published online and provided in English or an easily translatable format, making it easier for businesses to access and understand applicable rules.

Businesses will have the right to request an advance ruling on tariff classification, valuation and rules of origin. These rulings must be issued within 90 days, giving companies advance clarity on how their goods will be treated at customs enabling more informed business planning.

The FTA includes comprehensive provisions on financial services, professional services, digital trade, and e-commerce. The mutual recognition frameworks for professional qualifications are expected to facilitate cross-border mobility of professionals alongside the dedicated digital trade chapter ensuring the free flow of data, reducing barriers for technology-driven businesses.

The FTA also provides market access to public procurements in certain GCC jurisdictions, including Bahrain and the UAE, offering UK businesses an opportunity to compete for government contracts.

The next steps involve finalising and legally validating the FTA text, followed by the formal signing by the UK and all GCC member states. The FTA will enter into force once it has been ratified by all parties.

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The Monetary Authority of Singapore (MAS) announced that the revised framework for Single Family Offices (SFOs), which provides a simple, streamlined process for SFOs to establish operations in Singapore, was brought into force on 15 June.

The revised framework creates a straight through class exemption from licensing for all qualifying SFOs operating in Singapore, regardless of structure. SFOs that meet the requirements need only notify MAS of their operations and maintain an account with a MAS-licensed bank. They also have to file an annual return with information on the total assets under management and the name of their bank.

This revision follows a public consultation on the revised SFO framework and the policy responses by MAS to the industry’s feedback published in November 2024. Existing SFOs operating in Singapore will have a transitional period of one year to comply with the revised framework.

To operate in Singapore under the licensing exemption framework an SFO must only conduct fund management for, or on behalf of:

• Family members, including family trusts and corporations wholly owned by, and for the sole benefit of the family.
• Charitable organisation(s) funded exclusively by the family.
• Key employees (Executive Directors, Chief Executive Officer, Chief Financial Officer and investment professionals). Assets originating from key employees must not exceed 10% of the total value of the SFO’s assets under management in aggregate.

An SFO can be held via a trust, foundation or any other legal structure, provided the funding of the SFO originates exclusively from members of the same family, whether directly or indirectly, and key employees, who are permitted to own a non-controlling stake of up to 10%.

An SFO must be incorporated in Singapore and the SFO and its fund vehicle(s) must each open and maintain a bank account with a MAS-licensed bank. Foreign incorporated fund vehicle(s) may open and maintain an account with a MAS-licensed bank in Singapore, or with a regulated bank in a jurisdiction that complies with equivalent anti-money laundering and countering of financing of terrorism (AML/CFT) requirements consistent with Financial Action Task Force (FATF) standards.

The term ‘family member’ refers to all lineal descendants of a common ancestor (living or deceased) who are up to five generations removed from the youngest generation that established the SFO in Singapore, including:

• Current or former spouses.
• Adopted children.
• Stepchildren.
• Parents-in-law.
• Siblings-in-law.

It is not MAS’ intention to license SFOs because, unlike licensed fund managers, they manage their own assets or assets belonging to members of the same family. A new SFO must simply file a Notice of Commencement of Business with MAS within 14 days of commencement of its operations in Singapore. An existing SFO that intends to continue operating in Singapore will have one year from 15 June 2026 to satisfy the conditions under the licensing exemption and to file the Notification.

An SFO is required submit its first annual return within four months from the end of its current financial year, in respect of that financial year. There is no requirement to submit an annual return in respect of the SFO’s previous financial year prior to Notification.

A service provider can submit the Notification and annual returns on behalf of an SFO. The Notification must be accompanied by a copy of the declaration signed by a family member who provided the assets to be managed by the SFO, and a director of the SFO. Only one signatory is required if the family member is also a director of the SFO. The service provider cannot provide the signed declaration on behalf of the SFO. Electronic signatures are accepted.

An SFO must ensure that it is able to satisfy all the conditions of the exemption, before submitting its Notification. There is no requirement for an SFO to seek legal advice to support its qualification under the exemption or to provide a legal opinion when submitting its Notification. An SFO is not required to provide the name of its legal adviser as part of the Notification.

“The revised MAS framework is a welcome development for Singapore’s Single Family Office ecosystem, particularly in moving towards a clearer and more practical notification-based regime. While legal advice is no longer formally required as part of the notification process, families should still take care to ensure that the structure, governance, banking arrangements and ongoing compliance are properly thought through from the outset,” said Andrew Galway, Managing Director of Sovereign Management Services in Singapore.

“This is where experienced partners can add real value. At Sovereign, we are well placed to help families navigate the practical implementation of a Singapore SFO, coordinate with suitable professional advisers where needed, and introduce appropriate Singapore banking partners. The framework may be simpler, but getting the structure right at the beginning remains important.”

Banks are also required to conduct the AML/CFT checks on SFOs and their fund vehicles. The customer due diligence and ongoing monitoring checks conducted on an SFO should be subject to the bank’s risk-based approach when it establishes a business relation with its customer.

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The governments of the Hong Kong Special Administrative Region (HKSAR) and the Republic of Cyprus announced the signing of a comprehensive double taxation agreement (DTA) on 12 June aimed at eliminating double taxation on income and combating tax evasion and tax avoidance.

In-scope taxes include Hong Kong profits tax, salaries tax and property tax and Cyprus income tax, corporate income tax, capital gains tax and special defence contribution.

Business profits are generally taxable only in the country of residence, unless the company operates through a permanent establishment (PE) in the other jurisdiction. Where a PE exists, profits must be attributed based on the arm’s length principle, reflecting functions, assets and risks. This aligns with international OECD standards and provides a consistent framework for transfer pricing.

Under the DTA, any tax paid by Hong Kong residents in Cyprus will be allowed as a credit against the tax payable in Hong Kong in respect of the same income, subject to the provisions of the Inland Revenue Ordinance (Cap. 112) (IRO). Similarly, Cyprus residents can offset Hong Kong taxes against their Cyprus tax obligations.

The agreement provides that dividends and interest income will not be taxable at source. For cross-border passive income, dividends will generally be taxable only in the recipient’s jurisdiction, while interest will be taxed only where the beneficial owner resides. Cyprus withholding tax rates for Hong Kong residents on royalties will be reduced from 10% to 3%.

For real estate investments and holding structures, gains from immovable property or from shares derived mainly from real estate will be taxed where the property is located. Other gains will generally be taxed in the investor’s country of residence

For individuals, the treaty clarifies that employment income will generally taxed in the country where the employment is exercised but a 183-day rule allows exemption in short-term assignments under certain conditions. This provides flexibility for expatriates and cross-border professionals.

The DTA includes provisions intended to counter tax base erosion and profit shifting. It also includes a Principal Purpose Test (PPT) to counter treaty abuse, prevent the artificial avoidance of permanent establishment status, neutralise the effects of hybrid mismatch arrangements and improve dispute resolution mechanisms.

The agreement will enter into force after the completion of domestic ratification procedures by both states. It will then be effective for Hong Kong from 1 April of the year following its entry into force and in Cyprus from 1 January of the year following its entry into force.

“Cyprus is a participant in the Belt and Road Initiative and an important trading partner of Hong Kong in Europe. This CDTA sets out the allocation of taxing rights between Hong Kong and Cyprus, which will enable investors to better assess their potential tax liabilities from cross-boundary economic activities and avoid double taxation. This will help promote bilateral trade and investment,” said Hong Kong Secretary for Financial Services & the Treasury Christopher Hui.

“This is the 58th CDTA that Hong Kong has concluded and also the third one this year, signifying the HKSAR Government’s ongoing achievements in expanding the CDTA network. We will continue to actively seek to sign CDTAs with more tax jurisdictions to enhance the attractiveness of Hong Kong as a business and investment hub.

Mingson Chi, Client Accounting manager at Sovereign Trust (Hong Kong), said. “Cyprus offers access to EU markets, while Hong Kong serves as a springboard into Mainland China and Asia. This agreement effectively creates a tax-efficient bridge between the two regions.

“The favourable treatment of dividends and interest makes this treaty highly attractive for holding companies, treasury centres and private equity and investment funds. With royalties capped at 3%, businesses can also explore IP licensing structures with significantly reduced withholding tax exposure.”

For further information or to find out how this new DTA may impact your business or cross-border investments, please contact Mingson by phone on +852 2542 1177 or by email below.

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The Malta government published Legal Notices 84 and 86 of 2026 on 1 April, which are designed to make enhancements to the Value Added Tax (VAT) and gaming tax frameworks under Maltese law. These changes, which respond directly to feedback received from the gaming industry following extensive consultation, will enter into force on 1 October.

Malta is making targeted amendments to the VAT Act (Cap. 406 of the Laws of Malta), with the Malta Tax & Customs Administration (MTCA) issuing supporting Guidelines to establish a reliable VAT framework for the sector.

The scope of the VAT exemption for the supplies of gambling will be clarified, particularly in relation to sports betting and certain casino offerings, alongside guidance on how the place-of-supply rules apply for such offerings. This ensures that the principle of taxation at the place of consumption is adequately reflected.

The delimitation of the exemption on such services will lead to a natural right of recovery of eligible input VAT costs, providing for a fair and simple mechanism for the protection of the neutrality of VAT for gaming operators.

In parallel, the Malta Gaming Authority (MGA) is amending the gaming tax framework under the Gaming Tax Regulations (Subsidiary Legislation 583.10) issued under the Gaming Act (Cap. 583 of the
Laws of Malta) to complement the new VAT rules. The main changes include:

• Simplified and equitable gaming tax rates for both land-based and online operators when offering qualifying gaming activities to players present in Malta.
• Consolidation of the existing gaming tax and gaming device levy into a single, streamlined gaming tax structure classified according to game type and mode of offer.

This reconfiguration of the gaming tax framework is specifically designed to ensure a well-balanced overall impact on Malta’s gaming services sector and will apply exclusively to gaming services provided within the territory of Malta.

“The reforms form part of the government’s broader commitment to safeguard the long‑term sustainability, competitiveness and regulatory certainty of Malta’s gaming industry, as announced in the 2026 Budget,” said Sebastien Philipona, Sovereign Group Head of Business Development for Malta and Cyprus.

“Taken together, these coordinated reforms deliver a clearer and more predictable tax framework for operators and represent a measured and forward‑looking policy response that strengthens Malta’s fiscal resilience, regulatory clarity and international standing as a leading gaming jurisdiction.”

Further information will be issued in due course by the MTCA and the MGA to support implementation and ensure clarity for all affected stakeholders.

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For companies operating in logistics and maritime trade, international exposure is no longer an exception, it is the norm. Freight forwarders, shipping company, shipping operators, and integrated trading groups routinely manage cross-border contracts, operations, global clients, multi-currency flows, and operations spanning several jurisdictions.

In practice, we increasingly see large organisations in logistics and maritime that:

• operate across multiple regions but remain structured through a single main entity,
• manage international contracts, financing, and risks without clear separation,
• have grown rapidly, with their structure lagging behind their operational footprint.

When Operations Outpace Structure

As businesses expand globally, a number of challenges naturally begin to emerge.

• decision-making, legal risk, and profitability concentrated in a single entity,
• limited distinction between operations, management, and ownership,
• increasing scrutiny and corporate governance from banks, insurers, and counterparties,
• difficulties in supporting further expansion, financing, or long-term careful planning.

Left unaddressed, these situations can lead to pressure on banking relationships, reduced flexibility in accessing financing and increased financial risk, and growing complexity when engaging with investors, auditors, or regulators.

At this point, growth is no longer constrained by operational capability, but rather operational effectiveness and the importance of a clear structure.

Structure Is Not About Entities

International structuring is often misunderstood as a discussion about jurisdictions or legal vehicles. In reality, it is more about alignment and it starts with more fundamental questions:

• Where are strategic decisions truly made?
• How are risks distributed across the group?
• Where is value created, managed, and controlled?
• Is governance aligned with the operational reality of the business?

Only once these elements are clearly understood does it become relevant to determine where the right jurisdiction is and how the corporate structures should be part of the solution.

From Operational Efficiency to Institutional Credibility

Moving from a single, centralised operating model to a more aligned and structured framework often represents a turning point for logistics and maritime groups.

An example is one of our clients in the international shipping sector, whose operational footprint spans multiple jurisdictions. As the business expanded, ownership, investment, and financing functions were separated from day-to-day operations through a dedicated Mauritius holding company. Hong Kongs acts as the main fleet manager entity and is the groups commercial management centre, while regional activities are coordinated from India. This structure aligns ownership, governance, and operational responsibilities across the group, creating a clearer framework for growth, financing, and risk management.

In this context, Mauritius serves as part of the wider corporate architecture rather than the centre of operations. The jurisdiction provides a platform through which investments, vessel-owning entities, and capital management can be coordinated, while operational activities remain located closer to customers, assets, and key markets.

Any fiscal efficiency achieved is typically a consequence of a coherent structure, not its primary objective.

Mauritius as Part of a Broader Framework

Due to its strategic position between Africa, Asia, Europe, and the Middle East, Mauritius is often recognised for international trade and as a foreign direct investment hub. However, for many logistics, maritime, and trading groups, its value extends beyond it’s geographical connection to different countries.

As businesses expand across multiple jurisdictions, the focus increasingly shifts from where operations take place to how ownership, governance, financing, and risk are structured across the group. In the example above, while India remains an important operational hub and Hong Kong serves as the centre for commercial shipping activities, Mauritius provides an additional layer of value through its role as a holding and investment platform.

For companies involved in ship management, logistics, supply chain operations, cargo, and global trade, Mauritius is therefore often considered not simply because of its location, but because of its ability to support a more aligned international structure. When combined with appropriate governance, substance, and operational alignment, it can serve as a neutral coordination platform for managing cross-border investments, ownership, and capital within a growing international group.

How we Support International Structuring

At Sovereign Group, we support international logistics, maritime, and trading groups by focusing first on structure, governance, compliance and alignment with reality.

We are often brought into discussions at the stage where businesses recognise that their operational footprint has become international, but their structure has not yet evolved accordingly.

With nearly 39 years of experience and a presence in 23 jurisdictions worldwide, our role is to help build frameworks that are credible, sustainable, and aligned with how the business truly operates.

The most successful logistics companies are not only those that move goods efficiently across borders, but those that recognise when their business has become truly international and ensure that their structure evolves accordingly.

For leadership teams, the question is no longer simply how to grow, but whether the underlying structure is ready to support that growth over the long term.

If you have interest in understanding how Mauritius might fit into your company structure, contact us. We can assist with corporate structuring, corporate governance, how double taxation treaties can be leveraged and give you a realistic overview of entity setup and delivery timelines to begin operations on the island.

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The most successful outcomes for residence-by-investment planning almost never come from pursuing a single, isolated option. Most often, success is achieved through a holistic approach that integrates more than one solution – the most advantageous residency routes, the most beneficial tax and wealth planning, and mobility strategies that align with a client’s wider lifestyle, business and family goals.

A recent article in Investment Migration Insider (IMI) makes this point clear: a place of residence can provide access but not flexibility, a passport can provide mobility but not structure, and a tax base can provide efficiency but not long-term settlement.

According to IMI, today’s investors are now therefore converging around three functional layers:

• Mobility – a fast-track citizenship that provides immediate global access.
• Tax base – a jurisdiction offering efficiency, predictability and structural flexibility.
• A European anchor – a long-term residency driven by stability, lifestyle, business and opportunities.

No single programme can provide all three dimensions. Portugal’s Golden Visa can certainly be advantageous, but current waiting times are long and over recent years the Portuguese government has increasingly shifted the programme’s focus onto investors who bring long term economic value in skills or investment. This year it has also extended the timescale for acquiring Portuguese citizenship.

This may mean that, for some applicants, the Golden Visa is unlikely to deliver all three objectives in one go. A single path could turn out to be a dead end, while a combination of solutions can build resilience and offer clients the long-term security and opportunity that they are seeking for themselves and their families.

Such applicants should consider adding shorter term mobility and tax residence options to their current planning to ensure that they maintain flexibility; others may decide to look at other beneficial European programmes, such as Cyprus, Malta, Greece and Italy, or further afield to the UAE.

“At Sovereign, we don’t just sell visas. Our expertise in cross-border corporate and private client services means we can design solutions that integrate residence and mobility options with tax, wealth and succession planning across multiple jurisdictions,” said Shelley Wren, Head of Business Development at Sovereign Portugal.

“The question is no longer ‘which visa should I apply for?’ but ‘which combination of residence, tax and mobility solutions is likely to deliver the best long-term outcomes?’ Sovereign has four decades of experience and a global network of expertise to help develop comprehensive planning that can adapt to change.”

If you’re considering Portugal’s Golden Visa or are already in the scheme and unclear about the implications of recent changes, then contact Sovereign Portugal to review your plans and assess your answers to the following questions:

• How does this fit with my existing tax position and residency status?
• Do I need additional options in other jurisdictions to preserve flexibility?
• Am I planning for mobility, family needs and multi-generational goals, and not just a single passport?

For further information, please contact Shelley Wren.

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The Sovereign Art Foundation (SAF) is delighted to announce the winners of the Sovereign Student Art Prize Guernsey.

This year’s prize celebrated 29 finalists, each nominated by their teachers in recognition of the exceptional quality of their work. The prize is designed to recognise the importance of art in education and to shine a well-deserved spotlight on the talent being produced by young people across the island.

The Winners

The Sovereign Art Foundation Judges’ Prize, carrying a personal award of £800 for the student and a £2,000 grant for their school, was awarded to Poppy Bowen from Blanchelande College for her piece ‘Home’.

Inspired by a visit to the Lofoten Islands in Northern Norway, the work is deeply personal. Poppy describes the composition as

representing an escape and a portal into a new world, with elements from her travels brought together into something close to perfect. At its heart is a fjord, where land meets sea, and the hummingbirds woven through the piece are a tribute to her Nana, lost to cancer in 2021, for

whom a trip to Norway had always been a dream. Poppy made that journey for her. It is the kind of work that reminds us why art matters.

The Sovereign Art Foundation Public Vote Prize saw the Guernsey community respond with real enthusiasm, generating nearly 800 votes, a testament to the engagement and support that this prize continues to inspire across the island. The winner, as chosen by the public, was Adam Walter, also from Blanchelande College, for his piece ‘Petit Bot Passageway at Low Tide’.

Discovered during a kayaking trip, Adam was drawn to the location by its strong composition, leading lines and range of tones and colours. Working from photographs taken across multiple viewpoints, he painted in acrylic on canvas, using square-ended brushes and palette knives to build up the paint in varying thicknesses – a technique that brings real texture and depth to the finished work. Adam receives £400, with a grant of £1,000 awarded to Blanchelande College.

Congratulations to both Poppy and Adam, and to Blanchelande College on a remarkable double win.

“We are incredibly proud to celebrate the talent, creativity and dedication shown by all of this year’s participants. The standard of work continues to be exceptional and highlights the importance of supporting young artists at every stage of their development. Initiatives like this provide meaningful opportunities and exposure for emerging talent in Guernsey.”
Martin-Dale Bradley, Managing Director, Sovereign Trust (Channel Islands) Ltd.

Part of a Global Network of Charitable Work

The Guernsey Student Prize is one of twelve Student Prizes run by SAF around the world, spanning Bahrain, Chester, Cyprus, Gibraltar, Guernsey, the Isle of Man, Malta & Gozo, Mauritius, London, Portugal, Hong Kong and Singapore. The Foundation was established in 2003 by Howard Bilton and Tiffany Pinkstone, with a founding vision of celebrating artists while raising funds for programmes that use art to make a meaningful difference in communities.

For Sovereign Guernsey, support for the prize goes beyond sponsorship. As a business that has been part of the island’s professional community for many years, there is a real sense of responsibility to invest in the people and talent that make Guernsey thrive, and celebrating the next generation of artists feels like a natural expression of that commitment.

Congratulations to All 29 Finalists

While the prizes rightly celebrate individual achievement, every one of the 29 finalists deserves recognition. To have their work selected and celebrated among peers, family and the wider community is a remarkable achievement in itself.

Sovereign Guernsey is proud to support this prize and looks forward to continuing to nurture the next generation of artistic talent on the island.

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Private Trust Companies (PTCs) can be a highly effective vehicle for managing trusts for families or connected groups. In this article, we explore the key aspects of PTC regulation in Guernsey, including limited permissions, fiduciary licensing and record-keeping requirements.

What is a Private Trust Company (PTC)?

A PTC is a ‘special purpose’ company that is formed for the purpose of acting as a a trustee of a specific trust or a group of connected trusts. These are usually a trust or trusts set up for one family, or unit trusts that do not fall under the remit of the Protection of Investors (Bailiwick of Guernsey) Law 2020.

There is no dedicated PTC legislation in Guernsey. Most PTCs are formed as companies limited by shares and are incorporated in the same way as any other Guernsey company.

Acting as trustee is a regulated activity in Guernsey under the Fiduciaries Law. However, PTCs are generally exempt from the full licensing requirements that apply to companies carrying on trust business in Guernsey if they are granted permission by the Guernsey Financial Services Commission (GFSC) to operate with ‘limited permission’.

The GFSC provides clear guidance on the regulatory framework for PTCs under the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc. (Bailiwick of Guernsey) Law 2020.

Limited Permission for PTCs

PTCs fall within the scope of the Fiduciaries Law and therefore must either apply for a fiduciary licence under section 6 of the Law or seek limited permission under section 3(1)(ac) to operate without a licence. Limited permission will depend on the facts and circumstances of each individual case but may be granted based on the following criteria:

• • The PTC will act only as a trustee to specific trust or a group of connected trusts with common interest, such as trusts for one family.
  • The PTC will not advertise or market its services to the public.
  • The PTC will be administered by a licensed fiduciary under the Guernsey Fiduciaries Law.
  • The licensed fiduciary confirms to the GFSC that it will retain sufficient knowledge and information about the PTC’s ownership and control structure and about its activities to be satisfied that:
    1. The PTC is effectively administered and governed.
    2. The PTC complies with relevant laws and regulatory requirements.

The licensed fiduciary can demonstrate an appropriate level of oversight of the PTC by any, or a combination of, providing a director to the board of the PTC, or providing a company secretary or authorised signatory to the PTC.

As the licensed fiduciary is facilitating the carrying on of a regulated fiduciary activity by the PTC, the GFSC regards this as a higher risk activity under the Proceeds of Crime Law, which should be subject to enhanced monitoring and oversight that is commensurate with the Money Laundering, Terrorist Financing and Proliferation Financing (AML/CFT/CPF) risks involved.

Applications can be submitted via the GFSC Application Portal, accompanied by applicable fees. Permissions are typically granted for three years and can be renewed if no changes occur in the information submitted at application.

Full Fiduciary Licensing for PTCs

Some PTCs may prefer to apply for a full fiduciary licence, especially if they have sufficient expertise and robust AML/CFT/CPF frameworks in place. Holding a full licence can provide reassurance to beneficiaries and third parties, such as banks or insurers, that the PTC is under GFSC supervision. Such licences may be subject to conditions limiting the scope of the PTC’s activities.

Private Trust Foundations (PTFs)

The GFSC also considers applications for limited permissions for Private Trust Foundations (PTFs). Similar criteria apply to PTFs as those for PTCs, and applications can be submitted through the GFSC Application Portal.

Record-Keeping Requirements for Licensed Fiduciaries

Licensed fiduciaries should ensure that they maintain detailed records of the PTCs or PTFs they administer, which should be available for inspection by the GFSC on request. This should include:

• Each trust’s activities.
• Any beneficial ownership information regarding the PTC, its directors/ councillors and its controllers.
• Any information regarding the settlors, beneficiaries and, if applicable, protectors of the trust or trusts.

Advantages of a PTC

PTCs offer a range of benefits to families with complex assets or family succession issues who are seeking to move away from direct ownership to a structure designed to offer coherency for the future but are concerned that a traditional family trust will not allow them sufficient control.

This may be an issue either because they want to retain a degree of control over the management of their assets or are unable to find a suitable service provider to act as trustee because the assets placed in trust, such as a family business, are seen as too complex or high risk for an independent trustee to manage.

PTCs offer a tailored solution for families and connected groups to manage their trusts. They can serve to unite a family’s business interests and thereby strengthen control whilst at the same time achieving segregation between different assets.

They allow family members to retain an element of influence over the management of the trust assets, through the board of the PTC, without compromising the validity of the family trusts. And they can facilitate the devolution of control to future generations.

Licensed fiduciaries, like Sovereign, play a crucial role in overseeing PTCs and maintaining compliance with Guernsey’s laws.

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The States of Guernsey’s Tax Review Sub‑Committee confirmed, on 11 March, that it had removed territorial corporate tax from the list of options under consideration as part of the ongoing review of Guernsey’s tax system.

For businesses operating in or from Guernsey, this decision provides welcome clarity and reinforces the island’s commitment to a stable and predictable tax environment, writes Leigh Higgins, Operations Director at Sovereign Guernsey.

What is a territorial corporate tax?

Under a territorial corporate tax system, companies are generally taxed only on profits arising from activities carried out within the local jurisdiction. Profits generated from activities outside the territory are typically excluded from tax. While this approach is used in some countries, it can involve complex rules around where profits are considered to arise and how activities are defined.

Guernsey currently operates a well‑established corporate tax regime that is familiar to international business, administrators, and regulators, and which has been designed to meet international standards while supporting the island’s role as a leading international financial centre.

Why was the proposal rejected?

At a high level, the Tax Review Sub‑Committee concluded that a territorial corporate tax did not offer a sufficiently balanced outcome at this time. In reaching its decision, it considered expert input, feedback from the public consultation, and a broad assessment of risks and benefits.

Key concerns included the potential complexity of operating a territorial system, uncertainty over how it would be perceived internationally, and the risk of unintended consequences for Guernsey’s competitiveness and established business models. Against this backdrop, the Sub‑Committee decided to narrow its focus to other options and to exclude territorial taxation from its options.

What does this mean for businesses?

The decision underlines continuity. There will be no immediate change to Guernsey’s corporate tax framework, and no new territorial tax rules for businesses to plan around or implement. For many clients, this provides reassurance that the island remains committed to tax certainty, international credibility and a business‑friendly environment.

More broadly, it signals that Guernsey’s approach to tax reform remains measured and consultative, with a strong emphasis on stability and long‑term sustainability rather than rapid structural change.

Looking ahead

The broader tax review process is ongoing, and the States will continue to assess how Guernsey’s tax system should evolve in response to international developments. We will monitor announcements and published recommendations closely and keep clients informed of any material updates. As always, businesses should stay engaged with their professional advisers to understand developments in context and consider any practical implications for their own arrangements.

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The Isle of Man Government published the latest sectoral risk assessment for the Trust and Corporate Service Providers (TCSP) sector on 11 March, alongside the overall the updated National Risk Assessment (NRA) for Money Laundering.

The Money Laundering NRA sits at the centre of the Island’s wider programme of National Risk Assessments, which also includes terrorism financing and proliferation financing, and reflects extensive collaboration across Government, regulators and industry partners.

It confirms that the Isle of Man’s overall money laundering risk remains Medium High, which is consistent with the findings of the previous 2020 assessment.

Despite the increasingly complex landscape of global financial crime, the Island continues to benefit from strong political and economic stability, as well as developed legal and regulatory frameworks which help maintain a stable risk profile.

The assessment reinforces that, as an international financial centre, the Isle of Man remains exposed to certain external risks including foreign predicate offences and complex multijurisdictional structures, and that ongoing understanding and management of these risks is essential.

The TCSP NRA confirms that the money laundering risk for TCSPs also remains Medium High, reflecting the sector’s international client base and its use of complex structures.

The assessment acknowledges strengthened controls since 2020, including enhanced supervision by the Financial Services Authority, thematic reviews and improved sector guidance, while identifying areas where continued focus will help maintain strong financial crime defences.

The TCSP sector remains economically significant, supporting domestic and international businesses and accounting for around 3% of national income.

Together, these assessments form an essential evidence base for the forthcoming National Action Plan and will guide future outreach and regulatory engagement. Regulated firms are required by legislation to incorporate NRA findings into their internal risk assessments, and industry can expect ongoing engagement from supervisors to support effective implementation.

“The publication of these assessments demonstrates our continued commitment to transparency, robust oversight and the responsible management of financial crime risks,” said Justice and Home Affairs Minister Jane Poole-Wilson.

“Maintaining a stable risk profile in an increasingly complex global environment reflects the strength of our regulatory framework and the collective efforts across the Island to safeguard the integrity of our financial system.”

The publication of the ML NRA and the TCSP sector assessments mark an important milestone in demonstrating the effectiveness of the Island’s anti-money laundering, framework and support ongoing engagement with international standards. Further sectoral assessments, including those for Legal Persons and Arrangements and for Virtual Asset Service Providers, will be published shortly.

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The Isle of Man government opened a consultation on proposals to extend access to the Isle of Man’s beneficial ownership register to “persons who can demonstrate a legitimate interest in accessing beneficial ownership information for the purposes of preventing, detecting, or investigating money laundering, terrorist financing and proliferation financing”.

The proposals follow a joint commitment by the three Crown Dependencies – the Isle of Man, Jersey and Guernsey – In December 2023 to enhance access to beneficial ownership information, with appropriate safeguards in place to protect privacy and personal safety. This outlined a plan to enhance transparency in line with the direction set by the European Union (EU) under the Sixth Anti-Money Laundering Directive (AMLD6), which is due to be transposed by EU Member States later this year.

The Isle of Man Central Registry is seeking feedback on how a legitimate interest framework could be introduced in a way that is effective, proportionate and operationally workable, and that reflects the Island’s legal framework and evolving standards in respect of access to beneficial ownership information. Key proposals within the consultation include:

• Introducing an application-based ‘legitimate interest’ access route, assessed case-by-case by the Central Registry.
• Defining the ‘interest test’ (legitimate purpose and necessity) and evidential requirements for applications.
• Setting the scope of information that may be disclosed where access is approved, limited to what is necessary and proportionate.
• Establishing safeguards and controls, including exemptions from disclosure in specified circumstances and restrictions on use.

“Beneficial ownership transparency is a cornerstone of global efforts to combat illicit finance. Transparency is embedded in the recommendations of the Financial Action Task Force (FATF), the international anti-money laundering watchdog,” said Kerry Scholes, Managing Director of Sovereign Trust (Isle of Man).

“Ensuring that the Isle of Man’s approach continues to align with evolving international standards is critical to maintaining the island’s reputation as a well-regulated international finance centre. The EU’s anti-money laundering policy committee MONEYVAL is to begin a mutual evaluation of the Isle of Man in September and will be looking closely at the jurisdiction’s progress in increasing beneficial ownership transparency.”

Officers across Isle of Man government continue to liaise with officers of the governments of Jersey and Guernsey, as well as the UK Home Office. Jersey launched a corresponding consultation last November and Guernsey in February 2026.

The details of each jurisdictions’ proposals vary depending on specific definitions of legitimate purpose and necessity, the evidential requirements for applications, limiting disclosure to what is necessary and proportionate, and appropriate safeguards, controls and exemptions to protect privacy and personal safety.

“These proposals are exploratory in nature”, said the Isle of Man government. “Their purpose is to examine how access could be structured in the future and to identify further considerations that would need to be addressed before any decision is taken on the most effective means of enhancing transparency.”

The Isle of Man’s consultation is a first step to gather views from industry. The consultation, which is being managed by the Department of Enterprise, will close on 30 June. After the consultation closes, the Department will review all responses received and a summary of consultation responses will be made available by the end of 2026.

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A Will remains the default estate planning tool for many Indian families. It is familiar, straightforward and is typically sufficient for simple estates and clear asset distribution. But in practice, a Will typically deals with succession too late because it takes effect only upon death, is subject to the sometimes lengthy and expensive probate process, is vulnerable to legal challenges, and generally lacks the flexibility to cater for family businesses, multiple assets and complex family dynamics.

These limitations are increasingly significant for Indian families whose wealth is no longer held only in India. Many high net worth Indians now have international operating companies, holding companies and investment portfolios based in international financial centres such as Singapore, the UAE, the UK or Guernsey, while family members, real estate and other assets may be spread across multiple jurisdictions worldwide.

In this context, succession planning is no longer just about who receives what. It is about maintaining control and continuity, structuring wealth for long-term protection and succession, while also providing tax efficiency and mechanisms for effective governance and dispute prevention. This might include setting up appropriate vehicles such as Trusts, Foundations, Companies and Partnerships.

Trusts are highly effective tools for asset management and protection, multi-generational succession planning, philanthropy, flexible distributions and provision for vulnerable beneficiaries.

The limitations of a Will

Indian succession law is complex because the applicable rules depend on religion, asset type and location, and whether the deceased left a valid Will. The Indian Succession Act 1925 can apply to all testamentary successions, but intestate successions (where no Will has been made) will be governed by the Hindu Succession Act 1956 or, for other religious communities in India, by distinct legal frameworks that reflect their religious laws and customs.

A properly drafted Will is still important. Recent Indian case law confirms that a Will is not automatically invalid merely because natural heirs, such as a spouse or children, are excluded. The Supreme Court has just reiterated (Parvathi Nairthi v Laxmi Nairthy 2026 INSC 521) that exclusion of natural heirs is not, by itself, sufficient to make a Will suspicious if the Will is otherwise genuine and legally sound.

But that does not mean a Will is dispute-proof. In many family situations, the real dispute is not just about legal entitlement. It is about perceived fairness, control of a business, influence of spouses, access to liquidity, family expectations or mistrust between siblings. A Will may express intention, but it rarely creates an operating system for how the family wealth should be managed after the founder is gone.

Matrimonial Risks

One area of high concern for Indian families is the risk that wealth intended for children or grandchildren becomes exposed to matrimonial disputes or pressure from in-laws. This needs to be approached carefully. A Trust should not be used to defeat legitimate claims, conceal assets or frustrate existing legal obligations. Courts can disregard transactions that are artificial, fraudulent or designed to deprive a spouse or creditor of proper legal rights.

Where assets are settled into a properly constituted Family Trust before any dispute arises, with independent trustees, clear beneficiary classes and genuine fiduciary administration, the Trust can help ensure that family wealth remains within the intended family line and is not fragmented by future personal events.

This is particularly relevant where parents wish to benefit a child without giving them outright ownership. Gifts or inheritances may be vulnerable to poor investment decisions, creditor risk, marital pressure or family disputes. A discretionary Trust can instead provide access to benefit without necessarily giving the beneficiary direct control or ownership of the underlying assets.

Indian matrimonial and domestic laws also recognise specific rights and protections, including a woman’s rights over ‘stridhan’ (a woman’s property) and protections under the Protection of Women from Domestic Violence Act 2005. This is why planning must be done transparently, with Indian legal advice, and with a clear distinction between legitimate long-term succession planning and any attempt to defeat existing legal claims.

High net worth families need structures, not documents

A modern family wealth structure is not just a document. It is a governance framework that is capable of responding to questions that a Will often leaves unresolved:

• Who should control the family business after the founder?
• Should all children benefit equally, even if only one works in the business?
• Should spouses be beneficiaries?
• Should in-laws have access to information or influence?
• How should distributions be made?
• Who decides if and when assets are sold?
• How are younger beneficiaries educated before receiving wealth?
• What happens if a child divorces, becomes insolvent or develops a dependency issue?

The importance of a Trust is that it separates economic benefit from legal ownership and control. The trustee holds the legal title to the Trust assets and administers them for the beneficiaries according to the Trust deed. In India, the Indian Trusts Act 1882 defines and governs private Trusts, while international families may also consider offshore (overseas) Trusts where assets, banking relationships and family members are located outside India.

Singapore Success

Singapore has become a leading jurisdiction for Asian family wealth because it combines legal stability, a sophisticated banking and professional services ecosystem and a regulated trust industry. Licensed trust companies in Singapore are governed under the Trust Companies Act 2005, and MAS states that companies carrying on trust business must hold a trust business licence unless exempt.

Singapore Trusts are built on English common law foundations but its framework has evolved through specific local legislation and progressive court rulings to become a leading global wealth management and succession planning hub. Singapore trust law is supported by the Trustees Act 1967, which sets out key trustee powers and duties.

From a practical perspective, this means an Indian family can establish a Singapore Trust to hold non-Indian assets such as investment portfolios, shares in offshore holding companies, family investment vehicles, or international real estate holding structures.

Singapore also offers tax and estate planning advantages in appropriate cases. Singapore completely abolished estate duty in 2008 and the Inland Revenue Authority of Singapore (IRAS) states that gains from the sale of property, shares and financial instruments are generally not taxable unless they are trading gains or otherwise income in nature.

For Indian families, Singapore is especially attractive where there is already a commercial nexus: regional business operations, investment portfolios booked in Singapore or family office activity in Asia. The Trust structure can also be paired with a Singapore private trust company, family office, investment committee, or holding company, depending on the family’s objectives and tax advice.

Guernsey Gain

Guernsey is another leading jurisdiction outside Asia for the establishment and management of Trusts. It is used by international families, particularly those seeking a common law environment, an effective judicial system, experienced fiduciary providers and strong banking and financial services sector.

Guernsey’s principal trusts legislation is the Trusts (Guernsey) Law 2007, which is supported by a body of case law from the Island’s courts. It is often used for cross-border estate planning and asset protection because Guernsey law accommodates non-resident settlors and beneficiaries, and provides protections against claims based on foreign forced heirship rules.

The Island further offers fiscal neutrality. Trusts with no Guernsey-resident beneficiaries are only liable to tax on Guernsey source income and Guernsey bank deposit interest is not treated as Guernsey source income when received by the trustees of a trust with no Guernsey-resident beneficiaries. This makes it a highly attractive platform for Indian families with assets in the UK, Europe, the Middle East or other financial centres, to operate alongside their Asian advisory and banking relationships.

Singapore or Guernsey

A Singapore Trust may be a suitable structure where the family’s assets, banks, advisers and next generation are Asia-focused. A Guernsey Trust may be more appropriate where the family wants a more European nexus, or continuity with existing international structures and advisers.

In some cases, a family may set up a Trust in one jurisdiction and position the underlying companies, investment accounts or holding vehicles in another jurisdiction. The key is to match the structure to the family’s circumstances: residency and tax residency, asset location, exchange control, future migration plans, family governance needs and the risk profile of the beneficiaries.

A practical structure for Global Families

A typical structure might include:

1. Family Trust – the Trust holds the family’s international wealth for a defined class of beneficiaries, such as children, remoter descendants and selected family members. The settlor decides how the assets in a Trust should be used. This is usually set out in a document called the ‘Trust Deed’, a very flexible instrument that can include directions to the trustee not to make distributions to beneficiaries whose assets are subject to attachment or need protection from marriage breakdown.
2. Underlying Holding Company – to hold bankable assets, shares in family investment vehicles, real estate holding companies or international operating interests.
3. Letter of Wishes – the Trust settlor sets out how they would like the trustees to manage the assets of the Trust and to provide guidance on which beneficiaries should benefit, when and on what terms. A Letter of Wishes can be changed at any time, without the cost and formality of amending the terms of the Will or Trust deed and, unlike a Will, can generally be kept confidential from the beneficiaries.
4. Family Governance Framework – a structure that sets out how a family makes decisions, how family members are kept informed and how family governance integrates with other structures such as a family Trust or family business. The framework typically consists of a family charter and a family council.
5. Indian Tax and Legal Review – for Indian resident settlors or beneficiaries it is essential to ensure that the Trust structure is genuine, properly administered and doesn’t create exposure to tax and potential claims, while protecting personal and business assets held in different jurisdictions with strategies tailored to cross-border requirements.

The Will is not enough

For high net worth Indian families with global assets, a Will is not likely to be sufficient or efficient on its own. A Will transfers assets after death, but a Trust can create a living governance framework that operates before and after death, across generations and jurisdictions.

Used properly, Singapore and Guernsey Trusts can help Indian families consolidate global wealth, reduce succession disputes, protect family assets from fragmentation and create a more disciplined framework for the next generation. The real value is continuity, governance, fiduciary oversight and clarity.

So the question should not be “Have you made a Will?” but “Have you created a structure that is capable of preserving multi-generational family wealth from deaths, divorces and disagreements?”

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