𝐂𝐡𝐢𝐧𝐚 𝐧𝐨𝐰 𝐭𝐚𝐱𝐞𝐬 𝐨𝐟𝐟𝐬𝐡𝐨𝐫𝐞 𝐭𝐫𝐮𝐬𝐭𝐬
It is time to rethink what trusts are really about

On  24 July 2026, China sent shockwaves through the international wealth planning community by issuing detailed rules on the taxation of offshore trusts.
The new rules introduce a 20% individual income tax across the establishment, operation and termination of offshore trusts. Chinese tax residents are taxed on gains realised when assets are transferred into an offshore trust, on trust income generated during its lifetime regardless of whether it is distributed, and on liquidation proceeds when the trust is terminated.

The rules also bring into scope undistributed income accumulated in offshore entities held or controlled by the trust.

Most headlines focus on another offshore tax loophole being closed.

I believe the more interesting question lies elsewhere.

For HNWIs and entrepreneurs, this is not the end of trust structures. They remain one of the most effective tools for international wealth and succession planning.
The reason is simple. International wealth planning has always been about combining the right jurisdictions.

A few weeks ago it was reported that Hong Kong overtook Switzerland as the world's largest offshore wealth hub. Some see this as a competition between financial centres.

I do not.

For years, international families have combined jurisdictions such as Hong Kong, Singapore, Switzerland, Liechtenstein, Jersey, the UAE and the United States within the same wealth structures.

I have advised on many such arrangements throughout my career. Each jurisdiction served a specific purpose within a structure designed around the family’s life, business interests and succession objectives.

The strategy was never defined by one jurisdiction. It lay in combining the right jurisdictions within a coherent international wealth and succession plan.
That is why I believe this development matters far beyond China. Above all, it highlights one thing:
Know your trust.

Understanding a trust means understanding the role it plays within the family's overall strategy and the contribution it makes across jurisdictions.
The strongest trust structures were designed to support families, preserve wealth across generations and provide the governance required for successful succession. International tax planning gives those structures the framework they need to work across borders.

Helping international families and entrepreneurs design exactly those structures is our passion. If this is a conversation you are having, let us talk.