Continuous Beneficiary Trust 100-Year Contract Exempt from Repeated Taxation, Bolstering High-Net-Worth Family Office Business
Taiwan's 'Continuous Beneficiary Trust' 100-year contract has reached cross-ministerial consensus on tax exemption. This means that under certain conditions, gift and inheritance taxes will not be repeatedly levied when beneficiaries change, which is expected to boost family office business for high-net-worth individuals.
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- 📰 Published: May 5, 2026 at 20:23
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Taipei, May 5 (CNA) The 'Continuous Beneficiary Trust' 100-year contract tax principle has gained cross-ministerial consensus. The Financial Supervisory Commission (FSC) explained that in the past, a tax was levied each time a beneficiary changed. In the future, for trust contracts with a duration of 100 years, tax will be levied at the beginning of the contract, and subsequent changes will not incur repeated gift or inheritance taxes under certain conditions. This is expected to drive the family office business for high-net-worth individuals. The principle will take effect once the Ministry of Finance issues its interpretive ruling on the continuous beneficiary trust tax principle.
Wang Yun-chung, Deputy Director-General of the FSC Banking Bureau, stated at today's regular press conference that developing Taiwan into an Asian asset management center involves family wealth transfer as a critical issue. The 'Continuous Beneficiary Trust' is an important trust system that allows for family asset succession and is very common internationally. In the past, due to unclear tax regulations in Taiwan, no institutions offered 'Continuous Beneficiary Trust' services, leading many industry players to propose suggestions.
Wang Yun-chung noted that the Ministry of Justice issued an interpretive ruling in 2023, confirming that within the current trust legal system, it is permissible to arrange for continuous beneficiaries in a trust contract, provided that a clear trust duration is agreed upon and beneficiaries can be ascertained. Subsequent generations can be designated as contingent beneficiaries, with conditions set for the acquisition and loss of beneficiary rights.
The 'Continuous Beneficiary Trust' refers to a trust model where, when a beneficiary dies or other conditions are met, that beneficiary's rights cease, and a subsequent beneficiary acquires the rights as stipulated in the trust contract.
For example, if a first-generation entrepreneur A entrusts family business shares to a trust, designating his son as the beneficiary, and the trust contract stipulates that upon the son's death, the first-generation entrepreneur's grandchild acquires the beneficiary rights, and so forth.
Wang Yun-chung pointed out that in the past, a gift tax or inheritance tax was levied each time a beneficiary changed. This time, the Executive Yuan convened a cross-ministerial meeting and discussed with the Ministry of Finance and the Ministry of Justice. They confirmed that when a beneficiary of a 'Continuous Beneficiary Trust' acquires beneficiary rights due to conditions met in the trust contract, if the trust contract and trust assets remain unchanged and meet certain requirements, then the acquisition of rights by a subsequent beneficiary, such as the first-generation entrepreneur's grandchild, is not considered a gift or inheritance, thus avoiding gift and inheritance taxes.
Media asked further: if the trust contract duration is set for 150 years, how will the portion exceeding 100 years be taxed?
Wang Yun-chung responded that the trust duration can certainly exceed 100 years. The current cross-ministerial conclusion is that the Ministry of Finance believes there should still be a specific time limit. Currently, it is confirmed that trust durations within 100 years can be exempt from repeated taxation. If the contract is extended nearing the 100-year mark through modification, subsequent handling will depend on the Ministry of Finance's interpretation.
According to statistics from the Trust Association, there are currently 55 institutions in Taiwan offering trust services, including banks, securities firms, and credit cooperatives, with domestic banks making up the majority. (Edited by Pan Yi-ching) 1150505
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Wang Yun-chung, Deputy Director-General of the FSC Banking Bureau, stated at today's regular press conference that developing Taiwan into an Asian asset management center involves family wealth transfer as a critical issue. The 'Continuous Beneficiary Trust' is an important trust system that allows for family asset succession and is very common internationally. In the past, due to unclear tax regulations in Taiwan, no institutions offered 'Continuous Beneficiary Trust' services, leading many industry players to propose suggestions.
Wang Yun-chung noted that the Ministry of Justice issued an interpretive ruling in 2023, confirming that within the current trust legal system, it is permissible to arrange for continuous beneficiaries in a trust contract, provided that a clear trust duration is agreed upon and beneficiaries can be ascertained. Subsequent generations can be designated as contingent beneficiaries, with conditions set for the acquisition and loss of beneficiary rights.
The 'Continuous Beneficiary Trust' refers to a trust model where, when a beneficiary dies or other conditions are met, that beneficiary's rights cease, and a subsequent beneficiary acquires the rights as stipulated in the trust contract.
For example, if a first-generation entrepreneur A entrusts family business shares to a trust, designating his son as the beneficiary, and the trust contract stipulates that upon the son's death, the first-generation entrepreneur's grandchild acquires the beneficiary rights, and so forth.
Wang Yun-chung pointed out that in the past, a gift tax or inheritance tax was levied each time a beneficiary changed. This time, the Executive Yuan convened a cross-ministerial meeting and discussed with the Ministry of Finance and the Ministry of Justice. They confirmed that when a beneficiary of a 'Continuous Beneficiary Trust' acquires beneficiary rights due to conditions met in the trust contract, if the trust contract and trust assets remain unchanged and meet certain requirements, then the acquisition of rights by a subsequent beneficiary, such as the first-generation entrepreneur's grandchild, is not considered a gift or inheritance, thus avoiding gift and inheritance taxes.
Media asked further: if the trust contract duration is set for 150 years, how will the portion exceeding 100 years be taxed?
Wang Yun-chung responded that the trust duration can certainly exceed 100 years. The current cross-ministerial conclusion is that the Ministry of Finance believes there should still be a specific time limit. Currently, it is confirmed that trust durations within 100 years can be exempt from repeated taxation. If the contract is extended nearing the 100-year mark through modification, subsequent handling will depend on the Ministry of Finance's interpretation.
According to statistics from the Trust Association, there are currently 55 institutions in Taiwan offering trust services, including banks, securities firms, and credit cooperatives, with domestic banks making up the majority. (Edited by Pan Yi-ching) 1150505
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Text, images, and videos on this website may not be reproduced, publicly broadcast, or publicly transmitted and utilized without authorization.