Trusts, Holding Structures and the Variable Capital Company: practical consequences

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The choice of vehicle follows from the purpose of the structure. A family that wants succession planning and protection against foreign forced heirship rules will choose a Singapore trust with a licensed trust company or a PTC as trustee. A family that also wants its investments managed professionally in Singapore will add a single family office and a VCC, while a regional group will use a holding company with real staff and decision-making in Singapore. Advisers should test any structure against the following questions:

Purpose: is the structure needed for succession, protection, governance or investment, and does each layer serve one of these purposes?
Governing law: is Singapore law adequate for the trust, given the 100-year perpetuity period and the absence of purpose trusts, or does part of the structure need another law?
Settlor control: are the powers reserved to the settlor limited to investment and asset management, and does the settlor’s conduct match the deed?
Trustee: is the trustee a licensed trust company, an exempt bank or a PTC that has engaged a licensed trust company for its anti-money laundering compliance?
Fund vehicle: does the VCC have a licensed or exempt manager, and does it meet the conditions of the section 13O or 13U incentive in each year?
Substance: do the holding company and the fund vehicle have staff, premises and decision-making in Singapore sufficient for section 10L and for the principal purpose test of the relevant treaties?
Corporate services: are directors and company secretaries appointed through a registered corporate service provider, and are the registers of controllers complete?
Reporting: has the structure been classified for the Common Reporting Standard and FATCA, and do the beneficiaries know that their countries of residence will be informed?
Exit: can the structure be unwound or moved without triggering tax in Singapore or abroad, and has the 60-day deregistration deadline been planned for any re-domiciliation?

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.