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Comparison of 5 major jurisdictions

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Comparison of 5 major jurisdictions

Jurisdiction	Hong Kong	Singapore	Cayman Islands	British Virgin Islands	Jersey
Trust Period	No perpetuity period	100 years	150 years	360 years	No perpetuity period
Settlor Reserved Powers Trust	Yes, only investment can be reserved by the Settlor	Yes, only investment can be reserved by the Settlor	Yes, the Settlor can reserve the following powers to themselves or to the Protector: Power to appoint or remove trustees; Power to appoint or remove beneficiary or alter the class of beneficiaries; Power to give investment direction to the Trustee regarding the investment of the trust fund; Power to vary, amend or revoke the trust instrument; Power of distribution of income and capital of the trust fund; Power to act as a director of the companies held under the trust; and Power to change the governing law or forum of administration.	Yes, the Settlor can reserve the following powers to themselves or to the Protector: Power to vary or amend the terms of the trust; Power to approve distributions to beneficiaries; Power to act as director of a company owned by the trust; or to direct the trustee to appoint or remove a director of such company; or to direct the trustee to exercise the voting rights of the shares of the company owned by the trust; Power of investment; To appoint or remove the trustee, protector, enforcer; To add, remove or exclude beneficiaries; and To change the trust’s governing law and forum of administration.	Yes, the Settlor can reserve the following powers to themselves or to the Protector: Power of investment; Power to remove and appoint Trustee; and Power to amend the terms of the trust instrument.
Asset Protection Legislation	No (Protected by Bankruptcy Ordinance, time limit according to Articles 49 to 51)	No	Fraudulent Dispositions Law	No	No
Power of Beneficiary to remove Trustee	Yes (Section 40A of Trustee Ordinance, unless Section 40D applies). Beneficiaries who are absolutely entitled to trust property are able to appoint and remove trustees	No	No	No	Yes, apply through Court
Power of Beneficiary to access to information	No restriction, refer to case law.	No.	No restriction, refer to case law.	No restriction, refer to case law.	Restrictions apply according to Article 29 of The Trusts (Amendment No. 7) (Jersey) Law 2018, disclosure of information.

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Comparison of 5 major jurisdictions

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