Singapore VCC insights

Private Trust Company Singapore: The Licensing Exemption, the Licensed-Trustee Condition and AML Duties

By VCC Editorial Team · Published 11 October 2026

Short answer: A private trust company in Singapore is a corporation that acts as trustee only for trusts of connected settlors and does not deal with the public. It is exempt from a trust business licence under the Trust Companies (Exemption) Regulations, but must engage a licensed trust company for AML/CFT checks and is subject to MAS Notice TCA-N03.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

A private trust company in Singapore lets a family hold the trusteeship of its own trusts, rather than appointing an unrelated licensed trustee. For families with complex holdings, such as operating businesses, a variable capital company (VCC) or concentrated positions, this keeps decision-making within a board the family can shape. This guide sets out the legal basis of the exemption, what the private trust company (PTC) must still do, and how it fits alongside a single family office, using the Trust Companies Act 2005, its subsidiary legislation and MAS publications checked on 11 October 2026.

What is a private trust company under Singapore law?

It is a corporation whose sole purpose is to provide trust business services for specific trusts of connected persons, and which does not solicit or serve the public.

Regulation 2 of the Trust Companies (Exemption) Regulations defines a private trust company as “a corporation (a) the purpose of which is solely to provide trust business services in respect of a specific trust or of specific trusts where (i) each settlor of such a trust is a connected person in relation to any other settlor of any other trust to which the corporation provides trust business services; and (ii) each beneficiary of such a trust is a connected person in relation to the settlor of that trust or a charity; and (b) that does not solicit trust business from, or provide trust business services to, the public”.

For an individual, a “connected person” means the persons listed in the Schedule to the Regulations, or a firm or corporation in which the individual or those persons together control at least 20% of the voting power. For a corporation, it includes current and former employees and directors and corporations meeting the same 20% test. A “charity” for this purpose is any trust, foundation, company or other body established solely for a purpose recognised as charitable by the governing law of the trust concerned. The Ministry of Law describes the Schedule as covering settlors connected to beneficiaries by blood or legal adoption; the exact list should be read in the Schedule itself before a structure is settled.

Why is a private trust company exempt from licensing?

Because it serves a closed family circle, not the public. MAS states that a company carrying on trust business under the Trust Companies Act 2005 must hold a trust business licence, and the exemption removes that requirement for PTCs.

The exemption sits in regulation 4(1)(a) of the Trust Companies (Exemption) Regulations, made under section 15(1)(d) of the Act: “For the purposes of section 15(1)(d) of the Act, the following persons shall be exempt … (a) any private trust company”. It is not in a schedule to the Act. Regulation 5(1) applies certain provisions of the Act, and regulation 16 of the Trust Companies Regulations, to exempt persons with the necessary modifications, so exemption from licensing is not exemption from all regulation.

Unlike banks, merchant banks and lawyers that rely on other exemptions, we found no requirement in the Regulations for a PTC to file MAS Form 8, the notice of commencement of trust business. Form 8 is tied to persons exempt under section 15(1)(a) or (b) and to lawyers under regulation 4(1)(b)(iv). MAS’s 29 May 2026 compliance toolkit for licensed trust companies and exempt persons likewise defines “exempt person” by reference to those categories, not PTCs.

Obligation	Private trust company	Licensed trust company
Trust business licence	Not required (reg 4(1)(a))	Required
Who it may serve	Specific trusts of connected settlors; beneficiaries connected or charities	The public
AML/CFT regime	MAS Notice TCA-N03	MAS Notice TCA-N03
Customer due diligence	Must engage a licensed trust company for trust administration services to conduct checks (reg 4(2))	Performed in-house
MAS Form 8 notification	No requirement found in the Regulations	Not applicable (licensed)
Corporate form	Must be a corporation; ordinary Companies Act 1967 duties apply to a Singapore company	Company licensed by MAS

What AML/CFT obligations apply to a private trust company?

Two layers apply: a licensed trust company must be engaged to carry out the checks, and the PTC itself is within MAS Notice TCA-N03.

Regulation 4(2) provides that “A private trust company shall engage a licensed trust company to carry out trust administration services for the purposes of conducting the necessary checks”. Failure is an offence under regulation 4(3). The licensed trust company therefore performs the due diligence on settlors, beneficiaries and controllers that the PTC would otherwise have to perform itself.

MAS Notice TCA-N03 on the prevention of money laundering and countering the financing of terrorism, dated 30 June 2025 and in effect from 1 July 2025, applies to “all trust companies licensed under section 5 of the Trust Companies Act 2005 … and all private trust companies exempted from licensing under section 15”. Some commentary describes the 2025 version as the first to bring PTCs within scope. That is not correct: the version last revised on 1 March 2022 already applied to exempt PTCs. The Ministry of Law confirms that TCA-N03, rather than the Trustees Act, is the AML/CFT regime for PTCs. Our guide to building a source-of-wealth file covers the evidence that the engaged trust company and the family’s banks will expect.

How do you set up a private trust company in Singapore?

The sequence is corporate first, then trust, then the licensed trust company engagement, then banking.

1. Confirm that every intended settlor is a connected person to every other settlor, and that every beneficiary is connected to the relevant settlor or is a charity.
2. Incorporate the PTC as a Singapore company under the Companies Act 1967, with a constitution limiting its objects to trust business for the specified trusts.
3. Decide who holds the PTC’s shares, and how control of the trustee will pass on the death or incapacity of a shareholder, so that the trusteeship is not disrupted.
4. Appoint a board with real trustee competence, and record how investment, distribution and conflicts decisions are taken.
5. Engage a licensed trust company under a written agreement to carry out trust administration services for the regulation 4(2) checks.
6. Settle the trusts, with the PTC as trustee, and keep beneficial ownership records as the Trustees Act 1967 and the Trustees (Transparency and Effective Control) Regulations 2017 require.
7. Open accounts and, where a single family office manages the trust’s assets, align the PTC’s and the SFO’s governance and records.

Our corporate secretarial affiliate, Singapore Secretary Services, handles incorporation and statutory registers for the PTC itself.

What protections does Singapore trust law give the settlor?

Section 90 of the Trustees Act 1967, inserted by the Trustees (Amendment) Act 2004, gives two protections relevant to international families.

First, a trust is not invalid by reason only of the settlor reserving to himself any or all powers of investment or asset management functions (section 90(5)). The protection covers investment and asset management powers; it is not a general licence for the settlor to retain control over distributions. Second, section 90(2) provides that “No rule relating to inheritance or succession shall affect the validity of a trust” in defined circumstances, which shields a Singapore-law trust from foreign forced heirship rules. Under section 90(3), the shield does not apply where the settlor is a Singapore citizen or domiciled in Singapore, and it applies only where the trust is expressed to be governed by Singapore law and the trustees are resident in Singapore. A Singapore PTC acting as trustee helps satisfy the residence condition. Our comparison of trusts, VCCs and family office structures considers when a trust is the right holding vehicle.

Trustees must also obtain, verify and keep information on beneficial ownership under the Trustees Act 1967 and the Trustees (Transparency and Effective Control) Regulations 2017, amended in 2025. These are record-keeping duties held by the trustee; they do not involve filing with a central register.

How are trusts with a private trust company as trustee taxed?

The answer depends on the trust’s classification, and the section numbers changed in the 2020 Revised Edition of the Income Tax Act 1947.

IRAS’s e-Tax guide “Income Tax Treatment of Trusts” (third edition, 30 January 2026) explains that foreign trusts are now dealt with in section 13F (formerly 13G) and prescribed locally administered trusts in section 13N (formerly 13Q). The guide itself excludes foreign trusts and locally administered trusts from its scope. IRAS records that, from 17 February 2006, the foreign trust exemption was extended to trusts administered by companies exempt from licensing under the Trust Companies Act. Whether a particular PTC-administered trust qualifies today turns on the current Income Tax (Exemption of Income of Foreign Trusts) Regulations, including the settlor and beneficiary tests added in December 2022, and should be confirmed with a tax adviser before the trust is settled.

Where the trust holds a fund with a section 13O or 13U award, the fund’s own incentive conditions continue to govern the fund’s income. Our guide to the annual evidence file for 13O and 13U covers those conditions.

Private trust company or single family office: which does a family need?

Often both, because they do different jobs. The PTC is the trustee that owns assets for beneficiaries; the single family office (SFO) manages investments.

A single family office relies on the MAS class exemption in force from 15 June 2026, with notification to MAS within 14 days and a MAS-licensed bank account. A PTC relies on the trust business exemption and the licensed trust company engagement. Combining them is common: the PTC holds shares in a VCC or holding company as trustee, and the SFO manages the portfolio. The governance documents must show which entity takes which decision, so that the PTC does not drift into fund management and the SFO does not exercise trustee discretions. Our note on choosing an SFO, MFO, EAM or private bank covers the investment side.

Frequently asked questions

Does a private trust company in Singapore need a MAS licence?

No. It is exempt from the trust business licence under regulation 4(1)(a) of the Trust Companies (Exemption) Regulations, provided it meets the definition of a private trust company.

Does a private trust company have to notify MAS?

We found no requirement in the Regulations for a PTC to file MAS Form 8, which applies to other exempt persons. The PTC must, however, engage a licensed trust company and comply with MAS Notice TCA-N03.

Can a private trust company serve two families?

Only if every settlor is a connected person in relation to every other settlor. Two unrelated families would generally fall outside the definition and require a licensed trustee.

Can a charity be a beneficiary of a PTC trust?

Yes. The definition allows each beneficiary to be either a connected person in relation to the settlor or a charity, as defined by reference to the trust’s governing law.

Is a PTC the same as a family office?

No. A PTC is a trustee; a single family office manages investments. Many families use both, with clear governance between them.

Sources

• Trust Companies (Exemption) Regulations, Singapore Statutes Online
• MAS Notice TCA-N03
• Ministry of Law: express trusts

Raffles Corporate Services helps family offices and fund managers with VCC incorporation, family office set-up and ongoing compliance, and incorporates and maintains the corporate records of private trust companies, working with licensed trust companies and our panel of Singapore law firms. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 11 October 2026. The Editorial Team, Variable Capital Companies Act.