How to set up a trust fund in 2026
Russia has no trust, and a personal fund opens only with assets from $1.2 million. How to set up a trust or foundation abroad, what establishment and upkeep cost, a trust for a child and what the Russian tax office requires.
In short
- A trust is not a company but an arrangement: a trustee holds the assets for your beneficiaries.
- Russia has no trust, and a personal fund can only be created with assets from $1.2 million.
- Setting up a simple trust or foundation abroad costs from $5,000, and about the same a year to run.
- For a child, a trust is set up with staged payments and a protector who oversees the trustee.
- A Russian settlor must notify the tax office; the fine for not doing so is about $5,900.
- A trust does not protect against existing debts, sanctions or criminal confiscation.
In detail
A trust fund is neither a fund nor a company. It is an arrangement: you hand assets to a trusted party, who manages them for the people you name - children, a spouse, future grandchildren. Russia has no such instrument in pure form, so families set up a trust abroad or use a Russian personal fund, which is only available with assets from $1.2 million.
Below is how a trust works, how it differs from a foundation, where it is set up in 2026, what establishment and upkeep cost, how to create a trust for a child and what duties a Russian settlor has towards the tax office. Amounts are converted at the rates of 6 October 2026: 84.93 roubles and 0.83 Swiss francs per dollar, 1 euro = 1.121 dollars.
What a trust fund is and how a trust differs from a foundation
A trust has no legal entity. The settlor transfers assets to a trustee, who holds them not for himself but for the beneficiaries. A private foundation, by contrast, is a legal entity with its own charter and council that owns the assets itself. Both are commonly called a trust fund, but they work differently.
| Feature | Trust | Private foundation |
|---|---|---|
| What it is | A legal relationship, an agreement | A legal entity |
| Who owns the assets | The trustee | The foundation itself |
| Who manages | A licensed trust company | The foundation council |
| Origin | Common law countries: Jersey, Guernsey, Cyprus, Gibraltar, the British Virgin Islands | Liechtenstein, Panama, Austria, Switzerland |
| Strength | Flexibility and strong creditor protection | Understood by banks and courts in civil law countries |
In a trust the settlor formally gives up control: the trustee decides, and the settlor can only write a letter of wishes. If nobody actually gave up that control, a court or tax office will easily treat the trust as a sham. A detailed comparison is in trust or foundation: which to choose.
Can you set up a trust fund in Russia
Russian law has no trust. The closest equivalents are trust management and the personal fund, and both differ markedly from a trust.
- Trust management. The owner hands assets to a manager under a contract but remains the owner. Such a contract gives no protection against creditors or inheritance disputes.
- Personal fund. Since 1 March 2022 a citizen can create a personal fund - a non-profit organisation that manages the assets transferred to it on terms set by the founder. The minimum at creation is about $1.2 million at market value. The fund can be created during life or by will, after the founder's death.
The personal fund handles passing a business to heirs inside Russia. But the assets stay in the Russian jurisdiction, and the $1.2 million threshold rules out most families. So for foreign assets and smaller sums families set up a foreign trust or foundation.
Where to set up a trust or foundation abroad in 2026
A jurisdiction is chosen not for its beaches but by three questions: where the beneficiaries live, which assets go into the structure and which bank will open its account. The most popular options are these.
| Jurisdiction | What is set up | Key feature |
|---|---|---|
| Jersey | Trust and foundation | The oldest trust practice, nominal foundation capital, licensed providers |
| Guernsey | Trust and foundation | Similar to Jersey, a small foundation registration fee |
| Cyprus | International trust | A Cyprus-resident trustee, creditor protection two years after the transfer |
| Gibraltar | Trust and private foundation | Foundations under a 2017 law, supervision by the financial regulator |
| British Virgin Islands | Trust | Convenient for holding companies, one of the most affordable prices |
| Liechtenstein | Foundation and trust | Foundation capital from $37,000, a minimum tax of ~$1,500 a year |
| Panama | Private foundation | Capital of $10,000 that need not be paid in at once |
Singapore is chosen by families with assets in Asia: trust companies there are licensed and supervised by the Monetary Authority of Singapore. An Austrian private foundation needs capital of about $79,000, notarial form and an annual audit, so it suits large family fortunes.
Each jurisdiction in detail: trusts and foundations in Jersey and Guernsey, the Cyprus international trust, trusts and foundations in Gibraltar.
How to set up a trust fund: a step-by-step plan
- Define the goal. Passing on a business, providing for children, creditor protection or dividing wealth between generations - everything else follows from the goal.
- Choose the jurisdiction and form. A trust if beneficiaries live in common law countries and flexibility matters. A foundation if banks and courts in continental Europe need to understand it.
- Choose the trustee or foundation council. It must be a licensed trust company, not a family friend. A protector is often added - a person who can replace the trustee and approves major decisions.
- Prepare the documents. For a trust, a trust deed and a letter of wishes; for a foundation, a charter and regulations.
- Pass the checks. The trust company and the bank verify the settlor and the origin of every rouble and dollar going into the structure.
- Transfer the assets. Usually the trust or foundation owns a holding company, which in turn holds accounts, the business and property.
- Open an account and notify the tax office. A Russian tax resident reports to the tax office the creation of a foreign structure and control over it.
The longest part is not registration but the source-of-funds check and opening the account: the bank wants to understand every participant in the structure and the path of every asset.
How much it costs to set up and run a trust fund
A trust is not a one-off purchase but a subscription: you pay every year for as long as the structure exists. Setting up an inexpensive structure starts at about $5,000, and roughly the same goes on annual upkeep. Below are Murblz support prices from our price list.
| Structure | Set-up | Upkeep a year |
|---|---|---|
| British Virgin Islands trust | from $5,300: establishment and trust documents | from $4,830 for trustee services |
| Seychelles private foundation | from $5,160: registration, charter and regulations | ~$6,300 including a council member |
| Cayman Islands trust | ~$1,380: registration and certificate | ~$595 |
| Liechtenstein foundation or trust | from $19,000 with administration | a manager will calculate it |
| Swiss family foundation | from $23,000 | a manager will calculate it |
| Austrian private foundation | from $17,000 | a manager will calculate it |
| Trust in Jersey, Guernsey, Cyprus or Gibraltar | a manager will calculate it | a manager will calculate it |
On top come foundation capital where the law requires it and the holding company's account. If the trust deed is drafted from scratch for a complex family, drafting alone costs about $10,000. A manager will calculate the exact amount for your assets and household in the chat.
Set-up from $5,000, but a mistake costs all the protection
The law does not forbid setting up a trust from a template and signing the documents. But mistakes cost more than any fees: a settlor who actually runs everything, a friend instead of a licensed trustee, assets moved after a debt arose, a forgotten notice to the Russian tax office. Each one turns the trust into a sham that creditors or heirs will challenge, or into a fine and extra tax. Murblz support removes these risks: we choose the jurisdiction and form for the family's goal, work with licensed partner trust companies, prepare the trust deed, the letter of wishes and the source-of-funds check, and handle the tax notices. We guarantee professional work and a transparent process, and in most cases a result on the first filing.
The cost of support depends on the jurisdiction, the assets and the family, and a manager will calculate it in the chat.
How to set up a trust fund for a child
A trust for a child is the most common request: parents want the money to wait until the heir grows up rather than go on the first flashy car. A trust does this better than a will, because the assets are already in the structure and probate does not touch them.
- The child is a beneficiary. While they are a minor the trustee manages the assets, and payments go to education, healthcare and living costs.
- Staged payments. The trust deed can provide for portions of capital, for example at 21, 25 and 30, or payments only for specific purposes.
- A protector. A trusted family person who can replace the trustee and approves major decisions.
- A letter of wishes. A non-binding note to the trustee on the family's values and how you see the child's future.
Forced heirship does not disappear, though. If other heirs live in a country that has it, they can challenge the transfer under their own law, so the family situation is reviewed before the trust is set up.
Who can be a settlor and a beneficiary
Any person with legal capacity who transfers their own assets and can prove their origin can be a settlor. Anyone can be a beneficiary: a spouse, children, grandchildren, descendants not yet born, a charity.
| Role | Who | What they decide |
|---|---|---|
| Settlor | The person transferring assets | The trust terms at creation |
| Trustee | A licensed trust company | Asset management and payments |
| Protector | A trusted family person | Replacing the trustee and major decisions |
| Beneficiary | Family members or a charity | Receives payments but does not manage |
Beneficiaries can have a fixed right to income or be discretionary - paid at the trustee's decision. Both tax treatment and how banks and tax authorities see the structure depend on this.
Taxes and CFC rules for Russian settlors
For the Russian tax office trusts and foundations are foreign structures without a legal entity, and controlled foreign company rules apply to them as to companies. The settlor is the controlling person if they can take the assets back, are a beneficiary themselves or actually run the structure.
- a Russian tax resident must notify the tax office of creating a foreign structure and controlling it;
- the profit of a structure controlled by the settlor can be attributed to them as controlled foreign company profit;
- payments to beneficiaries who are Russian tax residents are, as a rule, taxed as their income;
- the fine for not filing a controlled company notice is about $5,900.
Trusts and foundations take part in automatic exchange of tax information: the trustee or the account-holding bank reports, and the settlor, trustee, protector and beneficiaries are disclosed. Data exchange does not replace your own duty to declare the foreign structure. Controlled company rules are covered on controlled foreign companies.
What taxes the trust structure itself pays
In popular trust jurisdictions a trust set up by a non-resident for non-residents pays almost nothing locally. Tax arises where the settlor and beneficiaries live.
- Jersey and Guernsey. The trust itself is not a taxpayer. If neither the settlor nor the beneficiaries are island residents, tax is paid only on local-source income, and the standard corporate tax rate is 0%.
- Cyprus. An international trust is not taxed in Cyprus on foreign-source income if the beneficiary is not a Cyprus resident. There is no inheritance tax, and stamp duty on trust deeds was abolished for documents signed from 1 January 2026.
- Gibraltar. A non-resident's trust for non-residents is exempt from tax on income from outside Gibraltar. There are no capital gains, inheritance or gift taxes.
No local tax does not mean no tax at all. A Russian settlor who is the controlling person and resident beneficiaries report and pay under Russian rules, so the structure is built with the tax for each family member calculated from the start.
How a trust works in practice: the holding company
A trust has no legal personality of its own, so it does not open accounts or buy property itself: the trustee does everything in its own name. In practice the trust almost always owns a holding company, which holds the accounts, business stakes and property.
Banks like this set-up: they open an account for an ordinary company and see who stands behind it. Families like it too: when a generation changes, the trust's beneficiaries change, while the company and its accounts keep working without re-registration.
Trusts and inheritance: why it is faster than a will
When assets are already in a trust or foundation, there is no need to wait for probate after the settlor's death. The trustee keeps managing the assets and paying beneficiaries under the deed, and the business does not freeze for six months while heirs collect documents in several countries.
A foundation is better for holding company stakes across several generations: it has its own bodies and continues unchanged. A trust is more flexible when children from different marriages need different provision, or payments depend on study and age.
What changes for trusts in 2026-2027
- Data exchange is widening. Since 2026 a first wave of 46 jurisdictions has been collecting data under the extended automatic exchange and the crypto-asset reporting framework, with first exchanges expected in 2027.
- New EU beneficial ownership rules. From 10 July 2027 EU Regulation 2024/1624 applies: trusts are expressly included in registers, and access goes to authorities and those with a legitimate interest.
- Russia's list of exchange countries. By an order of 14 October 2025 the Russian tax office approved a list of about 80 jurisdictions for automatic exchange. The British Virgin Islands and Gibraltar dropped off it, and most Western countries do not exchange data with Russia. Your own duty to declare the structure does not go away because of this.
The conclusion is simple: in 2026 a trust is a tool for lawful inheritance planning and family protection, not a way to become invisible to the tax office. It is worth building with full reporting from the start.
How a trust protects against creditors
A trust's protection rests on time limits: the longer since the transfer, the harder it is for a creditor to challenge it. It only works for the future - moving assets after a debt arises is exactly what gets challenged.
- Cyprus. A transfer into an international trust can be challenged only on proven intent to defraud creditors existing at the time, and only within two years. The creditor bears the burden of proof.
- Cook Islands. A transfer is unchallengeable if more than two years have passed since the claim arose, and the claim must be filed on the islands within a year.
- Nevis. Before suing, a creditor posts a bond of about $100,000.
No jurisdiction protects against criminal confiscation, sanctions or asset freezes. A trust is a planning tool, not a refuge from existing claims.
Confidentiality: who will see your trust
Full anonymity ended about a decade ago. The question now is not whether the data exists but who sees it.
- Jersey and Guernsey. There is no central trust register, and the trust deed is not filed with any authority. Beneficial ownership registers cover companies and foundations, with no free public access.
- Cyprus. Since 2022 the trustee enters the settlor, protector and beneficiaries in a register, but it is not open: authorities, banks doing client checks and people with a legitimate interest see the data.
- Gibraltar. Trust data is closed to the public, while some beneficial owner details of foundations, as legal entities, are open.
- Panama. The foundation charter is public, while beneficiaries are recorded in a closed register.
Trust, foundation, personal fund or will: which to choose
| Instrument | Entry threshold | Creditor protection | Who it suits |
|---|---|---|---|
| Will | a notary fee | none | A simple inheritance within one country |
| Trust management in Russia | a contract with a manager | none | Managing assets without changing the owner |
| Russian personal fund | assets from $1.2 million | limited | Passing a Russian business to heirs |
| Foreign trust | from $5,000 to set up and the same a year | strong after 2 years in Cyprus | Families with assets and heirs in different countries |
| Foreign private foundation | from $5,000, capital under local law | depends on the country | Holding company stakes for generations |
Where people most often go wrong setting up a trust
- The settlor runs everything. Then a court or tax office treats the trust as a sham.
- The trustee is a friend, not a licensed company. Banks do not serve such structures, and creditor protection weakens.
- Assets are moved after a debt arises. Such transfers are challenged first.
- The Russian tax office is forgotten. Not filing a controlled structure notice costs a fine of about $5,900 per controlled structure.
- The trust holds assets directly. It is easier when the trust owns a holding company that holds the accounts and business.
- Forced heirship is ignored. Heirs can challenge the transfer under their own country's law.
When you do not need a trust fund
A trust is an expensive tool, and the honest answer about it is sometimes: you do not need one. Simple tasks have simpler solutions.
- You just want to pass a flat to your children. A will or a gift is enough.
- Assets are under a few hundred thousand dollars. Annual upkeep would eat a noticeable share of the income.
- The goal is to hide money from existing debts. Courts challenge transfers made after a creditor's claim arose, and protective time limits only work for the future.
- The settlor wants to keep full control. Then the trust is easily treated as a sham, and the tax office attributes its profit to the settlor.
But if the family has a business, property in several countries and heirs with different passports, a trust or foundation usually costs less than an inheritance dispute in three jurisdictions.
How we help
Murblz specialists choose the jurisdiction and form for the family's goal, work with licensed partner trust companies, and prepare the documents, the source-of-funds check and the notices for the Russian tax office.
Trusts
Jersey, Guernsey, Cyprus, Gibraltar, the British Virgin Islands and other jurisdictions.
Learn more →Private foundations
Liechtenstein, Panama, Seychelles, Austria, Switzerland: charter, council and registration.
Learn more →Jersey trust
A classic trust for family capital and inheritance.
Learn more →Cyprus trust
An international trust with creditor protection after two years.
Learn more →Controlled companies
Notices, profit calculation and returns for the settlor.
Learn more →Trust or foundation
Comparing the two forms on control, protection and tax.
Learn more →Does your family need a trust? Tell us about your assets, the countries where your heirs live and the goal. A Murblz specialist will tell you whether you need a trust at all, choose the jurisdiction and calculate the set-up and upkeep costs.
FAQ
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