Thailand’s private trust reform: Pathway to a tax-efficient regional wealth hub

What is a private trust? 

A private trust is an arrangement in which ownership of assets is legally separated from their control. Individuals transfer their assets to a trustee, who manages them for the benefit of designated beneficiaries in accordance with agreed terms and conditions. 

Status of private trusts in Thailand 

Thailand does not yet recognise private trusts under a general legal framework for wealth management purposes. Unlike common law jurisdictions, Thailand operates under a civil law system, where the concept of a trust is not broadly embedded in private law. 

Why does Thailand need to become a private trust hub? 

Developing a private trust hub is important for Thailand to remain competitive in attracting global wealth and investment. Key reasons include: 

• Attracting mobile global capital 
  Wealth held by high-net-worth individuals and family offices is highly mobile. A private trust regime can position Thailand as a destination for cross-border wealth.  
• Unlocking underutilised capital 
  Thailand hosts a large expatriate community and long-stay foreign residents. A well-designed structure could encourage these groups to deploy capital locally.  
• Strengthening the financial ecosystem 
  Establishing a trust framework supports the growth of asset management, legal, tax and advisory services, helping to deepen Thailand’s financial sector. 

Key features of the proposed framework 

Drawing inspiration from Singapore’s successful model while tailoring it to Thailand’s unique strengths, the AIMC’s proposal includes:  

• Establishing a legal structure for private trusts to strengthen investor confidence  
• Introducing competitive tax incentives to attract foreign capital inflows  
• Conditioning tax incentives on domestic investment through requiring foreign investors to allocate at least 10% of assets to Thai capital markets  

Additional measures under consideration also include:  

• Introducing long-term investment visas  
• Expanding eligible assets under residency programmes, including mutual funds  

Insights from Singapore’s success model 

Against this backdrop, Singapore provides a useful benchmark for how a well-designed private wealth framework can successfully attract global capital. 

Singapore’s success as a global wealth hub is built on a well-integrated approach that combines tax incentives, regulation and strong financial infrastructure. 

A key strategy is its attractive tax regime, which has made it a preferred destination for international investors. Key features include:  

• Tax exemptions on certain investment income  
• No capital gains tax  
• Preferential treatment for foreign-sourced income  

Importantly, these benefits are not offered without conditions. Singapore requires investors to demonstrate economic substance in the country, such as:  

• Establishing family offices  
• Hiring local employees  
• Incurring domestic spending 

This “capital-for-substance” model ensures that capital inflows generate tangible economic benefits, including job creation and industry development. As a result, Singapore has seen a rapid rise in family offices and now manages trillions of dollars in assets, reinforcing its position as a leading global wealth centre. 

Preparing for the future of private trusts 

As Thailand’s investment and regulatory landscape continues to evolve, at Forvis Mazars, we continue to monitor these developments and assist businesses and investors in optimising investment structures and navigating trust-related considerations.  

References:  

• Thailand targets foreign capital with key reform. Retrieved from Bangkok Post. 
• Thailand asset management group proposes private trust framework to attract global wealth. Retrieved from Asia Asset Management.