A private trust company (PTC) is a Singapore-incorporated company set up solely to act as trustee for the trusts of one family and its connected persons, exempt from holding a trust business licence. It suits high-net-worth families who want direct control over trustee decisions but is not the right answer for every family: this guide sets out the criteria that decide it.
What is a private trust company?
A private trust company is a corporation whose sole purpose is to provide trust business services to a specific trust or group of trusts settled by connected persons, typically members of the same family. Unlike a licensed trust company, which offers trustee services to the public for a fee, a PTC exists only to serve one family group and is prohibited from soliciting trust business from anyone outside that circle. Because of this narrow, closed purpose, Singapore law exempts a genuine PTC from the requirement to hold a trust business licence from the Monetary Authority of Singapore (MAS), provided it meets specific conditions on ownership, purpose and administration.
The PTC itself is usually a private company limited by shares, incorporated under the Companies Act 1967 in the ordinary way, and then appointed as trustee of the family’s trust deed or deeds. Its board of directors makes the trustee decisions that would otherwise sit with an external, licensed trustee, which is the main reason families choose this structure over engaging a licensed trust company directly.
Who a private trust company is for
A PTC is generally considered by families who already have, or are actively planning, more than one trust across generations, who hold concentrated or illiquid assets such as an operating business, private company shares, real estate or a family fund vehicle, and who want the family’s own representatives, alongside independent professionals, sitting on the board that makes trustee decisions. It is not designed for a single, simple trust holding liquid, diversified investments, where the cost and governance overhead of running a company as trustee will usually outweigh the benefit compared with appointing a licensed trust company.
Families already running a single family office (SFO) in Singapore often consider a PTC alongside it, since the two structures solve different problems: the SFO manages the investment mandate, while the PTC holds the legal and fiduciary role of trustee. For a broader comparison of when a family trust structure makes sense at all, see our related guide on Singapore trust structures for HNW families.
Eligibility and regulatory requirements
Under section 15(1)(d) and section 82 of the Trust Companies Act 2005, the Monetary Authority of Singapore has made the Trust Companies (Exemption) Regulations, which exempt a “private trust company” from the general requirement to hold a trust business licence. Regulation 4(1)(a) of those Regulations grants the exemption, and the Regulations define a private trust company as a corporation whose sole purpose is to provide trust business services to a specific trust or trusts where each settlor is a connected person in relation to any other settlor, and each beneficiary is a connected person in relation to the settlor or a recognised charity. “Connected person” is defined by reference to the Schedule to the Regulations, and broadly covers family members by blood or legal adoption, together with entities they control.
Two conditions matter most in practice. First, the PTC must not solicit trust business from, or provide trust business services to, the public: stepping outside the family circle breaks the exemption. Second, under regulation 4(2) of the Trust Companies (Exemption) Regulations, a PTC must engage a MAS-licensed trust company to carry out the trust administration services needed to satisfy anti-money laundering and countering-the-financing-of-terrorism checks, even though the PTC itself does not need a licence. The general law of trusteeship, including the powers and duties that attach to whoever acts as trustee, is set out in the Trustees Act 1967, which continues to apply to a PTC in its capacity as trustee in the same way it applies to any other trustee.
Because a PTC is a Singapore private company, it is also subject to ordinary company law obligations under the Companies Act 1967, including maintaining a register of registrable controllers and complying with beneficial ownership disclosure obligations under the Corporate Service Providers Act 2024 framework that governs the register of registrable controllers (RORC).
Cost and timeline
Indicative 2026 costs for setting up a Singapore PTC structure typically run as follows. Incorporating the PTC itself, including its constitution and initial company secretarial work, generally costs from S$3,500 to S$8,000. Drafting the family trust deed, or deeds if there is more than one trust, generally costs from S$15,000 to S$40,000 depending on the number of trusts, the complexity of the family’s assets and the number of beneficiaries and classes involved. Ongoing licensed trust administration services, which the PTC is required to engage under the exemption Regulations, typically run from S$24,000 to S$60,000 a year, on top of the PTC’s own annual corporate secretarial, accounting and audit costs.
On timeline, incorporating the PTC as a company usually takes one to two weeks once the directors and shareholders are identified and know-your-customer documentation is in hand. Drafting and finalising the trust deed, negotiating the board composition and appointing the licensed trust company for administration typically adds another four to eight weeks, so most families should budget a total of two to three months from a standing start to a PTC that is incorporated, has its trust deed signed and has its licensed trust company engagement in place.
Step-by-step setup process
- Confirm the family circle. Map every settlor and beneficiary against the “connected person” definition before committing to the structure, since a single unconnected beneficiary can break the exemption.
- Incorporate the PTC. Register a private company limited by shares under the Companies Act 1967, with a constitution that restricts its objects to acting as trustee for the family’s trusts.
- Decide the board composition. Most families combine family representatives with at least one independent, professionally qualified director experienced in trust governance.
- Draft the trust deed(s). Work with counsel to settle the trust instrument, appoint the PTC as trustee and define the powers reserved to the settlor, if any.
- Engage a licensed trust company. Appoint a MAS-licensed trust company to carry out the administration and AML/CFT checks required under the exemption Regulations.
- Fund and register the trust. Transfer the intended assets into the trust and complete any related company, property or fund registrations.
- Put ongoing governance in place. Set a board meeting cadence, a succession plan for directors and a periodic review of the family circle against the connected-person test.
Because a PTC is typically incorporated by a corporate secretarial provider before the trust deed is finalised, families sometimes engage the same team that handles their broader Singapore incorporation for foreigners, so the company formation and the trust deed workstreams stay coordinated. See our related guide on foreign director versus local resident director requirements for a Singapore Pte Ltd for the company-law side of appointing the PTC’s board.
Is a PTC right for you? Key questions to ask
Use these thresholds as a starting decision tree rather than a strict rule, since every family’s facts differ.
- How many trusts, and across how many generations? A single trust for one generation rarely justifies a PTC. Families planning two or more trusts across two or more generations get more value from the fixed cost of setting up the company.
- What is the asset profile? Families holding concentrated, illiquid or operating assets, such as a family business, private company shares or direct real estate, benefit from the board’s ability to make bespoke, informed decisions that a licensed trust company applying standardised policies may be slower to make.
- Is there already a single family office or comparable governance infrastructure? Families already running an SFO, typically once investable assets are in the tens of millions of Singapore dollars, usually have the governance capacity to also run a PTC board. Below that scale, the annual cost of licensed trust administration plus company secretarial and audit fees is harder to justify against a licensed trust company’s all-in fee.
- Does the family want board representation in trustee decisions? If the family is content with a licensed trust company making trustee decisions within an agreed investment and distribution policy, a PTC adds cost without adding much control. If the family specifically wants its own representatives at the table for material decisions, a PTC is the structure built for that.
- Can the family maintain governance discipline over time? A PTC only works if the board keeps meeting, keeps records and keeps testing the family circle against the connected-person definition as the family grows through marriage, adoption or new generations.
As a rough rule of thumb drawn from practitioner guidance, families with investable and business assets moving into a trust in the tens of millions of Singapore dollars, and an expectation of more than one trust over time, are where a PTC most often clears the cost-benefit bar; smaller or single-trust situations are usually better served by a licensed trust company.
Common mistakes and gotchas
The most frequent error is treating the PTC as a way to avoid all regulation: the exemption from licensing is conditional, not absolute, and a PTC that solicits business outside the family or skips its licensed trust company engagement risks losing the exemption and committing an offence under the Regulations. A second common mistake is under-defining the family circle at the outset, so that a later beneficiary, for example a child’s spouse or a step-relative, falls outside the connected-person definition and cannot be added without restructuring. A third is neglecting board governance once the PTC is set up: a dormant board that never meets, or that rubber-stamps decisions made informally by one family member, undermines the fiduciary discipline the structure is meant to provide and increases the family’s legal exposure if a dispute arises. Families should also budget realistically: PTCs are frequently under-costed at the outset by omitting the ongoing licensed trust administration fee, which is a recurring, not a one-off, expense.
Tax treatment also needs early attention. The Inland Revenue Authority of Singapore treats a Singapore trust, and the PTC that acts as its trustee, according to the underlying source and nature of the trust’s income, and families should take tax advice before assets are settled, not after.
FAQs
Does a private trust company need a MAS licence?
No. A genuine PTC that meets the conditions in the Trust Companies (Exemption) Regulations, including serving only connected persons and not soliciting business from the public, is exempt from the trust business licence requirement under the Trust Companies Act 2005, though it must still engage a licensed trust company for administration and AML/CFT checks.
How many trusts can one PTC administer?
There is no fixed numerical cap in the Regulations, but every settlor and beneficiary across every trust the PTC serves must satisfy the connected-person definition, which in practice limits the PTC to trusts within a single extended family group.
Who should sit on the PTC board?
Most families combine family members with at least one independent, professionally qualified director who understands trust and fiduciary duties, to balance family control with independent oversight.
Is a PTC cheaper than a licensed trust company?
Not usually, once incorporation, trust deed drafting, licensed trust administration and ongoing corporate secretarial and audit costs are added together. The case for a PTC rests on control and governance fit for complex, multi-generational or illiquid holdings, not on cost savings.
Does setting up a PTC affect personal income tax?
The PTC itself does not change how an individual family member’s own employment or investment income is taxed in Singapore; that continues to depend on tax residence and source rules under the Income Tax Act 1947. Families relocating key individuals to Singapore alongside setting up trust structures should also check personal tax residency rules, covered in our related guide on personal income tax for expats, resident versus non-resident.
Related guides
For a wider comparison of trust structures available to Singapore families, read our guide on Singapore trust structures for HNW families. For the company-law mechanics of the board that will sit on top of the PTC, see foreign director versus local resident director requirements for a Singapore Pte Ltd. Families weighing up their overall personal tax position alongside a new trust structure may also find it useful to read personal income tax for expats, resident versus non-resident.
Authoritative sources: the Monetary Authority of Singapore regulates trust business and publishes guidance on the Trust Companies Act 2005 and its exemption regulations; the Inland Revenue Authority of Singapore sets out the tax treatment of trusts and trustees; and the Law Society of Singapore can help families locate a qualified private client or trust lawyer to draft the trust instrument.
Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.