Services · Trusts & private foundations

Offshore trust: comparing jurisdictions

Updated 5 October 2026

We compare the trust laws of Jersey, Guernsey, Liechtenstein, Malta, Cyprus and Switzerland and choose the trustee and bank for the family's goal.

An offshore trust is a trust governed by the law of a country where neither the settlor nor the beneficiaries live. It is chosen for a reliable trust law, experienced trustees and courts with long trust practice. But the trust's jurisdiction does not set the family's taxes: those are still determined by the countries where the settlor and beneficiaries live. Choosing a jurisdiction is therefore a balance between trust law, trustee supervision, bank requirements and the participants' taxes.

Below: a comparison of the jurisdictions we work with under their laws, the selection criteria and the setup process.

Comparing trust jurisdictions

How to choose the jurisdiction

• Settlor control. Jersey and Guernsey expressly allow the settlor to reserve broad powers. But the more control, the more likely the settlor's home tax authority treats the assets as still theirs.
• EU or not. Malta and Cyprus offer an EU trust, convenient for European banks and families living in the EU, but with EU beneficial owner registers.
• Banks. Swiss banks work with trusts under foreign law, so a Jersey or Guernsey trust with a trustee in Zurich is a common choice.
• The alternative is a foundation. If the bank and family prefer a legal person with a charter and a board, compare with private foundations.

Who an offshore trust suits

• families with assets in several countries who need one structure and one set of succession rules;
• business owners who want to separate family wealth from company risks;
• parents who want to pass wealth to their children gradually, under a professional trustee;
• families from forced heirship countries who need to distribute assets differently from local rules.

What has changed for offshore trusts

Trusts are no longer anonymous. European countries keep trust beneficial owner registers, banks check every settlor's source of funds, and tax authorities automatically exchange account data. An offshore trust today is a tool for succession planning and risk protection, not a way to hide assets. That is why we start with the family's taxes and only then choose the country.

How to set up an offshore trust

1. Goal and taxes. We review the assets, beneficiaries, the control needed and taxes in the family's countries of residence.
2. Jurisdiction. We compare suitable countries and choose the governing law.
3. Trustee. We select a licensed trust company, which checks the settlor and the source of funds.
4. Deed. We draft the trust deed and letter of wishes and appoint a protector.
5. Assets and registers. We transfer the assets, open accounts and file beneficial owner information.

What we do

We compare jurisdictions for your goal, select the trustee and bank, draft the trust deed, support due diligence and the transfer of assets, and then administer the trust. The cost depends on the country, assets and trustee; a manager will calculate it in the chat.

What we do

• Offshore trust establishment and maintenance

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