Jurisdictions · British Virgin Islands
Family Office in the British Virgin Islands (2026)
The British Virgin Islands (BVI) has no family office licence or regime. Families mainly use BVI business companies, trusts, VISTA trusts and private trust companies (PTCs); a PTC needs no trust licence if it only does unpaid trust business or trust business for trusts whose beneficiaries are the settlor, the settlor's family or charities, and its registered agent holds a Class I trust licence. Deloitte (January 2025) reports that companies are generally exempt from income tax, that individuals have a zero-rated income tax and that there is no inheritance or estate tax, while payroll tax and stamp duty on land do apply. There is no investor residence programme: the Premier said in March 2026 that one was still being discussed, with no final decision, and the government says a Certificate of Residence is open after 20 years of ordinary residence. [1, 2, 3, 4, 5, 6, 7, 8, 9]
Best for: Families that want to hold BVI company shares in trust through a VISTA trust or a private trust company, in a place where, as Deloitte and Carey Olsen report, there is no income, capital gains, inheritance, estate or gift tax.
At a glance
| Licence | No family office licence; SIBA licence only for investment business 'by way of business' reported |
|---|---|
| Minimum wealth | No wealth minimum in SIBA or the private trust company exemption |
| Who counts as family | No legal definition; PTC trusts must benefit the settlor, connected persons or charities |
| Serving several families | No MFO licence; SIBA licence (USD 1,200 plus USD 1,800 a year) or trust licence |
| Law and courts | Common law; Eastern Caribbean Supreme Court with a Commercial Division; Privy Council |
| Substance | Economic substance test; pure equity holding companies meet a reduced test |
| Holding vehicles | Companies, PTCs, limited partnerships, VISTA and purpose trusts; no foundations |
| Corporate tax | Companies generally exempt from income tax; no Pillar Two law found (reported) reported |
| Family office tax | No family office tax regime found; companies generally pay no income tax reported |
| Personal income tax | Zero-rated income tax, no CGT (reported); payroll tax 8% employee plus 2% or 6% employer reported |
| Inheritance tax | No inheritance, estate or gift tax (reported); stamp duty if a non-belonger inherits land reported |
| Wills and succession | No forced heirship (reported); Trustee Act s.83A firewall against foreign heirship claims reported |
| Residence | No investor programme (under discussion, no decision); residence certificate after 20 years reported |
| Time to set up | No official company registration time; SIBA licence 2 to 4 weeks if simple (Harneys) |
| Official fees | Company USD 550 a year (up to 50,000 shares); PTC USD 1,500; SIBA licence USD 1,800 a year |
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Licence and who qualifies
How is a family office licensed in the British Virgin Islands?
No family office licence, registration or FSC guidance on single family offices was found. Under sections 3 and 4 of the Securities and Investment Business Act 2010 (SIBA), a person needs an FSC licence to carry on investment business in or from within the BVI, meaning an activity in Schedule 2, Part A (such as managing investments or giving investment advice) carried on 'by way of business' and not excluded by Schedule 2, Part B; a BVI business company doing so abroad is treated as doing it from within the BVI. The Schedule 2 exclusions could not be read in the official text: Mourant (24 February 2026) reports that a company is excluded where it does investment business exclusively with or for a company in the same group (subject to conditions, including receiving no pay for it), and a trustee where it acts for the purposes of, or in connection with, the trust (unless it is the trustee of a unit trust or acts as custodian); Mourant also says the Act gives no guidance on 'by way of business' and the FSC has published no guidance on interpreting the Act. A private trust company needs no trust licence under the Banks and Trust Companies Act 1990 if it only does unremunerated trust business or related trust business, does not solicit trust business from the public and its registered agent holds a Class I trust licence (Financial Services (Exemptions) Regulations 2007, paragraphs 5 and 6); Bedell Cristin reports that it does not register with the FSC and makes no annual reports or filings to it. [1, 2, 3, 10, 11, 12, 13]
Reported by the sources named, not confirmed by an official source.
What is the minimum wealth for a family office in the British Virgin Islands?
No minimum family wealth in the rules checked: the licensing test in sections 3 and 4 of SIBA turns on activities carried on by way of business, and the private trust company exemption in the Financial Services (Exemptions) Regulations 2007 contains no asset or wealth test. [1, 2, 10]
Who counts as family?
No legal definition of a family office was found. For the private trust company exemption, related trust business is trust business for one qualifying trust or a group of related qualifying trusts; every beneficiary of a qualifying trust must be a connected person of the settlor, a charity or the settlor (the settlor was added in 2013), and trusts are related where the settlor of one is a connected person of the settlor of the other. Connected persons are the settlor's spouse, descendants and their spouses, parents, grandparents, parents-in-law, siblings and their spouses and children, the spouse's grandparents and siblings (with their spouses and children), aunts and uncles and their spouses, first cousins, and nephews and nieces, including step and adopted relations (Financial Services (Exemptions) Regulations, Schedule Part I, paragraphs 1 to 4). The SIBA exclusion that Mourant reports turns on companies in the same group, not on family ties. [1, 2, 3, 11]
Can one office serve several families?
No dedicated multi-family office licence was found. An office managing or advising on other families' investments by way of business needs an FSC licence under SIBA, for example Category 3 (managing investments) or Category 4 (investment advice); from 1 April 2023 each sub-category costs USD 1,200 to apply and USD 1,800 a year. The lighter Approved Manager route lets a BVI company or limited partnership manage or advise private, professional and certain closed-ended funds, and other persons only if the FSC approves case by case; a manager whose assets under management exceed USD 400 million (or, for closed-ended funds, the amount in FSC guidelines) must notify the FSC and, within 3 months, fall back below it, apply for a licence or get FSC approval to continue. It costs USD 1,200 to apply and USD 1,800 for approval and each yearly renewal. Acting as trustee for other families needs a trust licence under the Banks and Trust Companies Act 1990 (Class I: USD 1,200 to apply, USD 19,200 a year), and Mourant reports a fine of up to USD 75,000 on conviction on indictment for a company carrying on unlicensed investment business. [10, 11, 14, 15]
Law, substance and vehicles
Which law and courts apply?
The Government of the Virgin Islands says the BVI is a common law jurisdiction and a member state of the Eastern Caribbean Supreme Court: the Supreme Court (commonly called the High Court) and the Commercial Division of the Supreme Court sit in the territory, appeals from the Supreme Court and the Magistrate's Court go to the Court of Appeal, and the Judicial Committee of the Privy Council is the highest court of appeal. Bedell Cristin (22 June 2026) reports a 2024 BVI High Court ruling in a commercial claim (BVIHC (COM) 2023/0064) that applied BVI law to an alleged trust of BVI company shares, and Carey Olsen (January 2026) says the Privy Council has recently held that shares in a BVI company are movable property. Financial services are licensed and supervised by the BVI Financial Services Commission (FSC), for example under the Securities and Investment Business Act 2010 and the Banks and Trust Companies Act 1990. [1, 6, 10, 16, 17]
What substance is required?
No substance rule specific to family offices was found. Under the Economic Substance (Companies and Limited Partnerships) Act, a BVI company or limited partnership carrying on a relevant activity (banking, insurance, fund management, finance and leasing, headquarters, shipping, holding, intellectual property, or distribution and service centre business) must have it directed and managed in the BVI, with adequate qualified employees, expenditure and premises there, and must carry out its core income-generating activity there. A pure equity holding entity, which only holds equity participations and earns only dividends or capital gains, meets a reduced test: it must meet its obligations under the BVI Business Companies Act or Limited Partnership Act and have adequate employees and premises in the BVI for holding equity participations. Investment fund business is not a relevant activity, holding debt for investment is not treated as finance business, and the International Tax Authority's rules say an entity that also holds other investments, such as interest-bearing bonds, is not a pure equity holding entity. [18]
Which holding vehicles are available?
BVI business companies under the BVI Business Companies Act 2004 (limited by shares, limited by guarantee with or without shares, or unlimited with or without shares), including private trust companies and restricted purposes companies, and limited partnerships under the Limited Partnership Act 2017. VISTA trusts under the Virgin Islands Special Trusts Act 2003 let a trustee hold BVI company shares indefinitely while the directors run the company, with no duty to monitor it except on an intervention call; at least one trustee must be a licensed trust company or a PTC. The Trustee Act provides for purpose trusts (sections 84 and 84A), which Carey Olsen says need an enforcer and are not subject to the rule against perpetuities, and lets a settlor reserve powers without invalidating the trust (section 86, replaced in 2021); Carey Olsen says BVI law has no foundations. Under the BVI Business Companies (Amendment) Act 2024, companies must file a copy of their register of members and their beneficial ownership information with the Registrar (the Registrar's guidance sets the threshold at individuals holding 10% or more and has the registered agent file it); the beneficial ownership register is not public, but from 1 April 2026 people who show a legitimate interest can apply for access. The Trustee (Amendment) Act 2024, in force since 10 December 2024, adds section 92B, under which trustees of applicable trusts must collect, verify and keep beneficial ownership information. [4, 6, 19, 20, 21, 22, 23, 24, 25, 26]
Tax
What is the corporate tax rate?
Deloitte (January 2025) reports that BVI companies are generally exempt from income tax, that there is no withholding tax on dividends, interest, royalties or fees for technical services, and that certain transactions of BVI companies owning BVI land bear stamp duty. No BVI law on the OECD Pillar Two global minimum tax was found (the FSC legislation library lists none to October 2026): Deloitte says the BVI had made no announcement on implementing the rules, and Orbitax reports that the 2025 Budget Address (11 November 2024) referred to evaluating their impact. No tax specific to holding companies appears in these sources. [5, 27, 28]
Reported by the sources named, not confirmed by an official source.
Are there tax incentives for family offices?
No tax regime specific to family offices was found. Deloitte reports that companies are generally exempt from income tax, so a family office company generally pays no BVI income tax, but staff working in the BVI bring payroll tax, social security and national health insurance contributions (see personal_tax). [5, 29]
Reported by the sources named, not confirmed by an official source.
Is there personal income tax?
Individuals pay no income tax: Deloitte (January 2025) reports a zero-rated income tax regime for individuals with no filing obligation, and Carey Olsen (January 2026) says there is generally no income or capital gains tax and that residence and domicile are generally not relevant to an individual's tax status; Deloitte reports no net wealth tax and Carey Olsen says there is no wealth tax, and no special regime for new residents was found. What applies is payroll tax, levied on employers and the self-employed, with the first USD 10,000 of each employee's yearly pay exempt; a Class 1 employer has payroll of no more than USD 150,000, turnover of no more than USD 300,000 and no more than 7 employees (Government of the Virgin Islands). Deloitte reports payroll tax of 8% for the employee (deducted at source) plus 2% (Class 1) or 6% (Class 2) for the employer (Carey Olsen gives 10% or 14% in total, of which 8% may be deducted from the employee), social security of 4% (employee) and 4.5% (employer) and national health insurance of 3.75% each, both capped, and no VAT or sales tax. [5, 6, 29]
Reported by the sources named, not confirmed by an official source.
Is there inheritance or estate tax?
There is no inheritance, estate or gift tax: Deloitte (January 2025) says there is no inheritance tax or estate tax, and Carey Olsen (January 2026) says there are no BVI estate duties, inheritance taxes or gift taxes. Land is the exception: a non-belonger who acquires BVI land by gift or inheritance needs a licence and pays stamp duty on the transfer, and a gift of land to a belonger out of natural love and affection bears USD 5 (Carey Olsen); Carey Olsen gives stamp duty on freehold land of 4% for belongers and 12% for non-belongers, on the higher of price and market value, and Deloitte reports the same two rates. Carey Olsen says a BVI grant of probate or letters of administration, or a resealed foreign grant, is needed to establish title to BVI assets. [5, 6]
Reported by the sources named, not confirmed by an official source.
Succession and residence
How do wills and succession work?
Carey Olsen (January 2026) says there is no forced heirship in the BVI, so a person domiciled there can leave property freely; a will must be signed by the testator before two witnesses present at the same time (no virtual witnessing), and intestate estates pass under the Intestate Estates Act. The Trustee Act firewall (section 83A, first enacted in 2004 and widened by the Trustee (Amendment) Act 2021) disregards heirship rights under foreign law over the property of a living person when deciding who owns property in a BVI trust (section 83A(14), as quoted by Bedell Cristin), protects trusts against foreign-law claims based on personal relationships such as marriage (section 83A(13)) and refuses to recognise conflicting foreign judgments, including one varying a BVI trust without the consent of its adult beneficiaries (section 83A(19)). Carey Olsen adds that a VISTA trust can avoid the need for a BVI grant of probate on the death of an owner of BVI company shares. [6, 17, 21, 22, 30]
Reported by the sources named, not confirmed by an official source.
Can the family get residence?
There is no investor or residence-by-investment programme. IMI Daily and BVI News (via IFC Review) report that on 5 March 2026 the Premier said the government was still discussing a residence-by-investment programme, first outlined in January 2025, with no final decision, investment threshold or launch date, and that the BVI cannot grant citizenship itself. The Government of the Virgin Islands says a Certificate of Residence is open to people who have ordinarily resided in the territory for 20 years, wish to live there and are of good character, and that Belonger status is open to holders of a Certificate of Residence or to a person married to a Belonger and living with them in the territory for five years. The Immigration and Passport (Amendment) Act 2024 (assented 1 November 2024, in force on a date to be set by notice, not seen) raises the ordinary residence needed for a Belonger certificate from ten to twenty years (government press release, 19 November 2024). No official route for wealthy non-workers or persons of independent means was found, and non-belongers need a licence to hold land (Carey Olsen). [6, 7, 8, 9, 31, 32]
Reported by the sources named, not confirmed by an official source.
Time and fees
How long does set-up take?
No official time for registering a BVI business company was found. An Approved Manager must apply at least 7 days before starting business and may then act for up to 30 days from the application (extendable by up to 30 days) while the FSC decides (Investment Business (Approved Managers) Regulations, regulation 4). Harneys (27 August 2026) reports that a straightforward SIBA licence application takes 2 to 4 weeks from complete submission, and complex ones 10 weeks to 12 months. [12, 15]
What are the official fees?
Indicative. Government fees for a BVI business company to incorporate and each year (BVI Business Companies (Amendment of Schedule 1) (No. 2) Order, 2022, S.I. No. 89 of 2022, in force 1 January 2023, Schedule 1 items for sections 7(1), 8(1) and 236; not changed by the 2024 and 2025 fee orders checked): USD 550 if it may issue no more than 50,000 shares, USD 1,350 above that, USD 1,500 or USD 3,000 for a private trust company (by the same share test) and USD 8,000 for a restricted purposes company. Before 1 January 2023 the amounts were USD 450, USD 1,200, USD 1,350, USD 2,650 and USD 7,500 (the annual fees as set by the earlier 2022 Order, S.I. No. 4 of 2022, in force 1 February 2022); Portcullis reported the new company and PTC amounts on 22 December 2022. Filing beneficial ownership information costs USD 125 and an initial register of members USD 50 (2024 Order); companies formed before 2 January 2025 had a USD 0 fee for these filings until 31 March 2026. FSC fees from 1 April 2023: SIBA Category 3 or 4 licence USD 1,200 to apply and USD 1,800 a year; Approved Manager USD 1,200 to apply and USD 1,800 for approval and each renewal; Class I trust licence USD 1,200 to apply and USD 19,200 a year. There is no family office licence, and Bedell Cristin reports that a PTC need not register with the FSC and that there are no application or annual fees to register as a PTC. [3, 14, 20, 33, 34, 35, 36, 37, 38, 39]
Private trust company
Does a private trust company need a licence in the British Virgin Islands?
Under paragraph 5 of Part I of the Schedule to the Financial Services (Exemptions) Regulations, 2007 (S.I. No. 50 of 2007, revised edition as at 1 January 2020), a private trust company is exempt from the requirement to hold a trust licence under the Banks and Trust Companies Act if its trust business consists solely of unremunerated trust business (no remuneration is payable to, or received by, the company or any person associated with it) or related trust business (trust business for a single qualifying trust or a group of related qualifying trusts). A private trust company is a limited company on the register under the BVI Business Companies Act whose memorandum states that it is a private trust company, and every beneficiary of a qualifying trust must be a connected person of the settlor (the settlor's family, as listed in the Regulations), a charity or the settlor (paragraphs 1 to 4). Under paragraph 6 it must at all times have a registered agent holding a Class I trust licence, must not solicit trust business from members of the public and must not carry on trust business of any other kind; it loses the exemption while it breaches these conditions (with 4 weeks' grace if its registered agent ceases to hold a Class I licence), and a company not entitled to the exemption must at once amend its memorandum to remove the private trust company statement (paragraph 7). The Financial Services (Exemptions) (Amendment) Regulations, 2021 (S.I. No. 3 of 2021, in force on a date set by notice, not seen) revoke the bar on non-trust business in paragraph 6(1)(b)(i), and Bedell Cristin (September 2021) says a PTC may now carry on some non-trust business. No change to the exemption in 2024 to 2026 was found in the FSC legislation library. [1, 2, 3, 13, 28]
Who supervises it, and what must it file?
The BVI Financial Services Commission (FSC). A private trust company does not register with the FSC or need its approval and makes no annual reports or filings to it (Bedell Cristin, September 2021; the Regulations contain no registration step). The Regulations deem its unremunerated and related trust business to be financial services business and apply some Financial Services Commission Act powers to it as if it were a licensee, so the FSC can, for example, appoint an examiner, issue a directive or require it to pay enforcement costs where it has breached the Act, the Banks and Trust Companies Act or the Regulations (paragraph 9). Its registered agent must notify the FSC in writing at once if it forms the opinion that the company does not comply with the business restrictions (paragraph 10(5)). [2, 3]
What local requirements apply?
The registered agent must at all times hold a Class I trust licence (paragraph 6(1)(a)). Before agreeing to act, the registered agent must take all reasonable steps to satisfy itself that the company complies, or will comply, with the business restrictions, must check again periodically at a frequency based on its own risk assessment, and must keep at its office in the BVI up-to-date copies of the trust deed or other document creating or evidencing each relevant trust (with any variation) and of the documents it relied on to confirm compliance (paragraph 10). Bedell Cristin (2021) says no local directors or local authorised representative are required. Mourant (January 2025) says that under the BVI beneficial ownership rules a private trust company exempted under these Regulations is not treated as a regulated trustee, so the exception for licensed trustees does not apply and it will have to file the beneficial ownership information. No source opened discusses private trust companies under the economic substance rules. [2, 3, 40]
What are the official fees?
Bedell Cristin (2021) says a PTC need not register with the FSC and that there are no application or annual fees to register as a PTC. Registry fees are higher than for an ordinary company: from 1 January 2023, the incorporation fee and the annual fee for a company whose memorandum states that it is a private trust company are USD 1,500 if it is not authorised to issue shares or may issue no more than 50,000 shares, and USD 3,000 if it may issue more than 50,000 shares, against USD 550 and USD 1,350 for an ordinary company (BVI Business Companies (Amendment of Schedule 1) (No. 2) Order, 2022, S.I. No. 89 of 2022, Schedule 1 items for sections 7(1) and 236, which raised the PTC amounts from USD 1,350 and USD 2,650; Portcullis reported the same figures in December 2022). The fee Orders of 2024 and 2025 checked do not change these amounts. The Orders print '$'; Portcullis gives the amounts in USD. [3, 33, 34, 35, 36, 37, 38]
Pros and cons
Pros
- There is no family office licence regime, and a private trust company that only acts for trusts benefiting a settlor's family (or acts unpaid) needs no trust licence, only a registered agent with a Class I trust licence.
- No income, capital gains, inheritance, estate or gift tax, as reported by Deloitte and Carey Olsen, and companies are generally exempt from income tax.
- VISTA trusts let a family hold BVI company shares in trust while the directors run the company, and the Trustee Act firewall disregards foreign heirship claims against BVI trusts.
Cons
- No investor residence programme: the government says a Certificate of Residence needs 20 years of ordinary residence, and in March 2026 a residence-by-investment scheme was still being discussed, with no final decision, thresholds or launch date.
- Payroll tax (8% for the employee plus 2% or 6% for the employer, as reported by Deloitte) applies to BVI staff, and non-belongers pay 12% stamp duty on land and need a licence to hold it.
- No official text deals with single family offices: whether a SIBA licence is needed turns on the 'by way of business' test, on which the Act gives no guidance (Mourant), and the group and trustee exclusions are known here only from law firm summaries.