Jurisdictions · Cayman Islands
Family Office in the Cayman Islands: Rules, Tax, Costs 2026
The Cayman Islands have no family office licence or family office tax regime. Since August 2020 a single family office is no longer listed as non-registrable under the Securities Investment Business Act, and Conyers says single family offices that conduct securities investment business must now be regulated under the Act, subject to certain exemptions; a private trust company serving connected persons registers with the Cayman Islands Monetary Authority (CIMA) instead of taking a trust licence. A Cayman Islands Government page says there is no income tax, company or corporation tax, inheritance tax, capital gains or gift tax, and PwC (May 2026) reports no direct taxation. Persons of independent means can get a 25-year residency certificate with CI$1,000,000 invested on Grand Cayman, at least CI$500,000 of it in developed real estate, plus income or a deposit, or a certificate of permanent residence with CI$2,000,000 in developed real estate. [1, 2, 3, 4, 5, 6, 7, 8]
Best for: Families who want to hold assets through Cayman trusts, including special (STAR) trusts, foundation companies or a private trust company registered with CIMA, and who may want long-term residence through the certificates for persons of independent means.
At a glance
| Licence | No family office licence; SIBA's SFO exemption repealed in 2020; PTCs register with CIMA |
|---|---|
| Minimum wealth | No wealth minimum in SIBA or the PTC rules; licensing turns on activities, not assets |
| Who counts as family | SIBA's family list repealed in 2020; PTCs serve connected persons only, not the public |
| Serving several families | No MFO licence; CIMA SIBA licence, or registration if only for HNW or sophisticated clients |
| Law and courts | Common-law courts; Grand Court Financial Services Division; final appeal to Privy Council |
| Substance | Economic substance test; reduced test for pure equity holding companies; funds excluded |
| Holding vehicles | Exempted companies, LLCs, foundation companies, partnerships, trusts, STAR trusts, PTCs |
| Corporate tax | No corporate income or capital gains tax; no minimum top-up tax law found |
| Family office tax | No family office regime; 20-year tax undertaking for exempted companies, plus 10 (PwC) reported |
| Personal income tax | No income, capital gains or wealth tax; import duty generally 22% to 27% (PwC); no VAT |
| Inheritance tax | No inheritance, estate or gift tax; stamp duty generally 7.5% on land transfers |
| Wills and succession | Full testamentary freedom (reported); Trusts Act firewall, sections 91 to 93 reported |
| Residence | 25 years: CI$1m invested, CI$500,000 in real estate, plus income or deposit; PR: CI$2m |
| Time to set up | No official figure found |
| Official fees | Exempted company from CI$700, annual from CI$925 (CI$1,025 from 2027); no FO fee |
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Licence and who qualifies
How is a family office licensed in the Cayman Islands?
There is no family office licence. Section 5 of the Securities Investment Business Act (2020 Revision, still the latest consolidated text) bars anyone from carrying on securities investment business unless licensed or registered under the Act or exempt; the activities in Schedule 2, caught when carried on in the course of business, include dealing in or arranging deals in securities, managing securities for another person with discretion and advising on securities. Schedule 2A, paragraph 2(d) made 'the conduct of securities investment business by a single family office' non-registrable, but a Cabinet Order made on 18 August 2020 repealed it, and the amending Acts of November 2020, 2023 and 2024 do not restore it. The remaining non-registrable categories include participants in a joint enterprise (and other companies in the same group) acting for that enterprise, and directors, partners or trustees acting in that capacity without separate pay (with further conditions), while a company carrying on such business exclusively for companies in its own group is listed in Schedule 4 among persons who must register with CIMA. Conyers (September 2020) says single family offices conducting securities investment business are now regulated under the Act, subject to certain exemptions. Bedell Cristin (March 2021) says the undefined phrase 'in the course of business' would seem to imply a view to profit, so that an office that only does what would otherwise be securities investment business for its own account, and not that of any third party, would seem not to be carrying on such business; no official text or CIMA statement saying so was found. The Private Funds Act (2025 Revision) lists single family offices among non-fund arrangements, which it excludes from the definition of a private fund. A private trust company doing only connected trust business needs no trust licence but must register with CIMA (Private Trust Companies Regulations (2026 Revision), regulation 4). [1, 2, 3, 4, 12, 13, 14]
What is the minimum wealth for a family office in the Cayman Islands?
No minimum family wealth in the Securities Investment Business Act (2020 Revision) or the Private Trust Companies Regulations (2026 Revision): whether a family office needs a CIMA licence or registration depends on its activities, and private trust company registration depends on serving connected persons, not on assets. Separate investment amounts apply to residence (see residency). [1, 4]
Who counts as family?
The Securities Investment Business Act no longer has a single family office category or a list of family members: the Cabinet Order of 18 August 2020 repealed that category and Schedule 4A, which listed the persons connected to an individual within a 'single family' (spouse; descendants and their spouses; parents and grandparents, including step-parents; parents-in-law; siblings and step-siblings and their spouses; the spouse's grandparents, and the spouse's siblings with their spouses and children; the parents' siblings and their spouses; and the children of siblings and of the parents' siblings, with their spouses). CIMA's Statement of Guidance on Non-Fund Arrangements (November 2020) describes a single family office as a legal entity or arrangement formed in the Cayman Islands by a single family to manage wealth for or on behalf of that family, without defining 'single family'. A private trust company may do only 'connected trust business' (regulation 2 of the Private Trust Companies Regulations defines it and 'connected person'), and under regulation 5 it must not solicit or receive contributions from the public or from persons who are not connected to each other. [1, 2, 4, 15]
Can one office serve several families?
No dedicated multi-family office licence was found. An office carrying on securities investment business for other families needs a CIMA licence under the Securities Investment Business Act, or registration as a registered person if it acts exclusively for sophisticated persons, high net worth persons (section 2: an individual with a net worth of at least $800,000, or any person with total assets of at least $4,000,000, or the equivalent in another currency) or companies, partnerships or trusts owned by them, and has a registered office or place of business in the Islands provided by a licensed provider (Schedule 4). The Securities Investment Business (Licence Applications and Fees) Regulations (2026 Revision) set, for a securities manager or securities advisor licence, an application fee of 1,000, a first-grant fee of 10,000 and an annual renewal fee of 10,000, and the Registration and Deregistration Regulations (2026 Revision) set a registration fee and an annual fee of 6,000 each for a registered person (neither text names the currency). A private trust company is exempt from the trust licence only for connected trust business, so trust business for unrelated families is outside that exemption. [1, 4, 16, 17]
Law, substance and vehicles
Which law and courts apply?
The Cayman courts administer justice under the Constitution, the laws of the Islands and the common law principles developed by local, British and other Commonwealth courts. The Grand Court is a court of unlimited jurisdiction for civil disputes, including complex commercial and trust matters, and its Financial Services Division, created in 2009, deals with the more complex civil cases arising from the financial sector, with specific procedures for companies and trusts; appeals go to the Court of Appeal and finally to the Judicial Committee of the Privy Council. PwC says English is the official language of the Islands; the court pages opened do not state the language of proceedings. [6, 18, 19, 20]
What substance is required?
No substance rule specific to family offices was found. Under the International Tax Co-operation (Economic Substance) Act (2026 Revision), a relevant entity carrying on a relevant activity (banking, distribution and service centre, financing and leasing, fund management, headquarters, holding company, insurance, intellectual property or shipping business) must conduct its core income-generating activities, be directed and managed appropriately in the Islands and have adequate expenditure, physical presence and qualified staff there. A pure equity holding company (one that only holds equity participations and earns only dividends and capital gains) meets a reduced test by confirming that it has complied with Companies Act filing requirements and has adequate human resources and premises in the Islands for holding and managing those participations; investment funds, and entities through which a fund invests, are not relevant entities, and every entity must notify the Authority each year. [21]
Which holding vehicles are available?
Companies (including exempted companies) under the Companies Act, limited liability companies, foundation companies, exempted limited partnerships, limited partnerships and limited liability partnerships, all with fee schedules at the General Registry, which also keeps a trust fee schedule. Part VIII of the Trusts Act (2021 Revision), 'Special Trusts: Alternative Regime' (sections 95 to 109), provides for special (STAR) trusts; Mourant (2026) says STAR trusts may be for persons, purposes or both, need at least one enforcer and at least one trustee that is a licensed trust company or a registered private trust company, and that a Cayman trust can be set up for an unlimited duration. Private trust companies register with CIMA and must keep their registered office at a company holding a trust licence (Private Trust Companies Regulations, regulation 3). [4, 9, 10, 11, 22, 23]
Tax
What is the corporate tax rate?
A Cayman Islands Government economy page (archived, undated) says there are no direct taxes in the Cayman Islands and no income tax, company or corporation tax, capital gains or gift tax, and PwC (last reviewed 29 May 2026) says corporate income, capital gains, payroll or other direct taxes are not imposed on corporations. PwC adds that a transfer tax equal to the applicable stamp duty applies to transfers of shares in land holding companies. No Cayman law introducing a global minimum tax or a domestic minimum top-up tax for large multinational groups was found in the sources opened, and PwC's Cayman pages mention none. On these sources a family holding company pays no Cayman tax on its profits or gains, but a pure equity holding company must meet the reduced economic substance test (see substance). [5, 6, 21, 24, 25]
Are there tax incentives for family offices?
No tax regime specific to family offices was found, as no direct taxes are imposed. PwC says an exempted company can apply under the Tax Concessions Law for an undertaking from the Governor-in-Council exempting it from any tax on profits, income, gains or appreciation introduced in the following 20 years, extendable for a further 10 years, and that exempted limited partnerships can apply under the Exempted Limited Partnership Law for a similar concession for 50 years. [5, 24, 26]
Reported by the sources named, not confirmed by an official source.
Is there personal income tax?
There is no personal income tax. A Cayman Islands Government economy page (archived, undated) says there are no direct taxes, no income tax and no capital gains tax, and no property taxes or rates; PwC (last reviewed 29 May 2026) says no income or withholding taxes are imposed on individuals and that there are no net wealth taxes, no VAT and no property taxes; Carey Olsen (2025) also says no income, capital gains, wealth, withholding, estate or inheritance taxes are levied. What does apply: PwC says import duty is paid on most goods, generally at 22% to 27%, and stamp duty on transfers of land and certain documents, generally 7.5% on transfers of Cayman immovable property (the Government page says 7.5 per cent in most areas, with reduced rates for Caymanians). [5, 20, 25, 27, 28]
Is there inheritance or estate tax?
There is no inheritance, estate or gift tax: a Cayman Islands Government economy page (archived, undated) says there is no inheritance tax or gift tax, PwC (last reviewed 29 May 2026) says there are no inheritance, estate and gift taxes, and Carey Olsen (2025) also says no estate or inheritance taxes are levied. Carey Olsen says stamp duty is levied on transfers of property at 7.5% of the purchase price, subject to a limited number of exemptions, and that a gift of Cayman real property 'for natural love and affection' to a spouse, child or grandchild may qualify for a waiver. No source opened sets out the stamp duty on land passing on death. [5, 20, 28]
Succession and residence
How do wills and succession work?
Carey Olsen (2025) says the Cayman Islands allow complete testamentary freedom, that under the Wills Act (2021 Revision) a will must be made by an adult over 18, in writing and signed in the presence of two witnesses, and that the Succession Act (2021 Revision) and Probate Rules (2008 Revision) govern intestacy. Part VII of the Trusts Act (2021 Revision) holds the firewall provisions: Bedell Cristin (March 2021) says section 91 (exclusion of foreign law) means a Cayman-law trust or disposition is not void or voidable because foreign law does not recognise trusts or because it defeats rights under foreign law based on a personal relationship or heirship, section 92 (heirship rights) means a foreign heirship right is not recognised as affecting the ownership of property, and section 93 means a foreign judgment is not recognised or enforced insofar as it is inconsistent with section 91 or 92. Mourant (2026) says these provisions cover foreign forced heirship, matrimonial and civil partnership claims. [9, 10, 20, 29]
Reported by the sources named, not confirmed by an official source.
Can the family get residence?
Persons of independent means apply under the Caymanian Protection Act (2022 Revision), the name of the Immigration (Transition) Act since 1 May 2026. The Residency Certificate for Persons of Independent Means (section 41) is valid for 25 years, renewable at the discretion of the Director of WORC, without the right to work; on Grand Cayman the holder must have invested CI$1,000,000, at least CI$500,000 of it in developed real estate there, and have annual income of at least CI$120,000 or a deposit of at least CI$400,000 in assets with a CIMA-regulated, locally licensed institution (on Cayman Brac or Little Cayman: CI$500,000 invested, CI$250,000 of it in developed real estate there, plus CI$75,000 income or the CI$400,000 deposit), and must declare each year that they spent at least 30 days in the Islands in the previous calendar year. The Certificate of Permanent Residence for Persons of Independent Means (section 42) needs CI$2,000,000 in developed real estate in the Islands, which since 1 May 2026 must be paid up (free of financing) at the time of application; the Government says the holder keeps it for 10 years, re-applies in year 9 for an indefinite certificate and only then can apply for naturalisation. It is granted without the right to work but can be varied to allow work in specified occupations, and Cabinet sets a gazetted quota. Dependants can be included in the application or added later. Under the fee schedule in force from 1 May 2026, the issue fee is CI$50,000 for the residency certificate (up from CI$20,000) and CI$200,000 for permanent residence (up from CI$100,000), plus CI$500 to apply, CI$500 for each annual declaration filing and CI$3,000 per dependant on issue and each year. The Government's reform FAQ says the financial requirements for persons of independent means have not changed and that this will be dealt with in a future amendment to the legislation. A Certificate of Direct Investment needs at least CI$1,000,000 invested in an employment-generating business (Immigration Regulations, 2018 Revision) and costs CI$50,000 to issue. [7, 8, 30, 31, 32, 33, 34, 35]
Time and fees
How long does set-up take?
Not found in official sources: the General Registry fee schedules opened state no time to register a company, foundation company or trust, and no official processing time was found for CIMA registration of a private trust company or for the residence certificates. [11, 22, 23]
What are the official fees?
Indicative, General Registry schedules effective 1 January 2025: registering an exempted company costs CI$700 (share capital up to CI$42,000) to CI$2,568 (above CI$1,640,000); the lowest annual fee band for an exempted company is CI$925, rising to CI$1,025 from 1 January 2027 (Companies (Amendment of Schedule 5) Order, 2026). A foundation company declaration costs CI$500, and the trust fee schedule lists a CI$500 registration fee and a CI$500 annual fee. A private trust company pays CIMA an initial registration fee of 3,500 and an annual fee of 4,000 (raised from 3,500 by regulations made on 17 December 2024), and a person that must register with CIMA under the Securities Investment Business Act pays 6,000 to register and 6,000 a year; these CIMA regulations say 'dollars' without naming the currency. There is no family office licence fee. [4, 11, 17, 22, 23, 36, 37]
Private trust company
Does a private trust company need a licence in the Cayman Islands?
A private trust company does not need a trust licence if it is registered with the Cayman Islands Monetary Authority (CIMA) under regulation 4 of the Private Trust Companies Regulations (2026 Revision, consolidated to 31 December 2025): regulation 4(1) says a registered private trust company does not require a licence to carry on connected trust business. The Regulations are made under the Banks and Trust Companies Act, which bars a trust company from carrying on trust business from within the Islands without a licence, subject to exemptions prescribed by regulations, and lets the Cabinet make regulations for registering private trust companies (sections 5(2) and 27(1)(d) of the 2020 Revision opened; the Regulations now refer to the 2025 Revision). A private trust company is a trust company incorporated in the Islands that carries on no trust business other than connected trust business, meaning trust business for trusts whose contributors are connected persons in relation to each other (regulation 2; the Schedule lists the family relationships, such as spouse or civil partner, descendants, parents, grandparents, siblings and in-laws, and a company and its beneficial owner, or companies in the same group, can also be connected). It must not solicit or receive contributions to its trusts from the public or from persons not connected to the other contributors (regulation 5), and its name must include 'Private Trust Company' or 'PTC' (regulation 6). Change in 2024: the Private Trust Companies (Amendment) Regulations, 2024 (SL 75 of 2024, in force 19 December 2024) raised the annual registration fee from 3,500 to 4,000; the exemption itself was not changed. [4, 37, 38]
Who supervises it, and what must it file?
The Cayman Islands Monetary Authority (CIMA). The private trust company must register with CIMA and, at registration and on or before 31 January every year, file an annual declaration (its name, its directors, its shareholders or members, the trust licensee providing its registered office, and a statement that it is a private trust company complying with the Regulations), file proof of identity of its directors and shareholders and pay the fee; it must tell CIMA of any change in that information within 30 days (regulation 4). CIMA may inspect documents at the registered office (regulation 3), may cancel the registration for false, misleading or inaccurate filings (regulation 4(3)), and may refuse or cancel registration if the company asks, or if CIMA has reasonable grounds to believe that the company or one of its principals is breaching the Anti-Money Laundering Regulations or other applicable law, or is not or is no longer fit and proper (regulation 4B). [4]
What local requirements apply?
The private trust company must keep its registered office at the office of a company holding a Trust licence under section 6(5)(c) of the Banks and Trust Companies Act, the licence for trust business within and outside the Islands (regulation 3(1)), and keep there, available to CIMA, up-to-date records for each trust, including its terms, trustee, settlor, protectors, enforcers, contributors, beneficiaries receiving distributions, variations and all financial and transactional records (regulation 3). A private trust company that registers, or changes its board, on or after 1 February 2019 must have a natural person as a director (regulation 4A); Mourant (2026) says there are otherwise no requirements on who may act as director. Breaching the records rule in regulation 3(2) or the annual filing rule in regulation 4(2) is an offence with a fine of five thousand dollars on summary conviction (regulation 7). No source opened says how the economic substance law applies to private trust companies. [4, 38, 39]
What are the official fees?
CIMA charges an initial registration fee of 3,500 and then an annual registration fee of 4,000 (regulation 4(2)(b); the Private Trust Companies (Amendment) Regulations, 2024 raised the annual fee from 3,500 with effect from 19 December 2024), a late surcharge of up to one-twelfth of the annual fee for every month or part of a month (regulation 4(2A)) and a fee of 300 on surrendering the registration (regulation 8). The Regulations write the amounts in words as 'dollars' without naming the currency; Mourant (2026) quotes the initial fee as CI$3,500 (US$4,268.29) and the annual fee as CI$4,057.37 (US$4,878.05), a CI$ figure that differs from the four thousand dollars in the Regulations. General Registry fees for the company itself are separate. [4, 37, 39]
Pros and cons
Pros
- Persons of independent means can get a 25-year residency certificate (CI$1,000,000 invested on Grand Cayman, at least CI$500,000 in developed real estate, plus CI$120,000 annual income or a CI$400,000 deposit) or permanent residence with CI$2,000,000 in developed real estate.
- A Cayman Islands Government page says there is no income, corporation, capital gains, inheritance or gift tax, and PwC adds that there is no estate tax, no wealth tax and no VAT.
- A private trust company serving connected persons registers with CIMA instead of taking a trust licence, and STAR trusts and foundation companies are available for family structures.
Cons
- The single family office category was removed from the Securities Investment Business Act's non-registrable persons in August 2020, so an office that manages or advises on securities must check whether it needs a CIMA licence or registration.
- Under the fee schedule in force from 1 May 2026, a residency certificate for persons of independent means costs CI$50,000 to issue and permanent residence CI$200,000, plus CI$3,000 per dependant on issue and each year, and neither certificate gives the right to work when granted.
- Stamp duty, generally 7.5%, applies to transfers of Cayman land and import duty, generally 22% to 27%, to most goods (PwC), and a pure equity holding company must meet a reduced economic substance test in the Islands.