Where to base a family office in 2026: Singapore, Switzerland, Dubai and the United States compared
Four places families actually choose between, compared on tax, substance, banking, privacy, reporting, residence and succession law.
General information, not advice.
What the office needs from a jurisdiction
Tax certainty on the fund's income, a banking system that will take the family, staff who can be hired, a regulator that is predictable, privacy that holds, a residence route for the principal if they want one, and succession law that will not surprise the children. No jurisdiction leads on all seven.
| Singapore | Switzerland | Dubai (DIFC, ADGM) | United States (SD, DE, WY) |
|---|---|---|---|---|
Fund tax | Exempt under 13O (S$20 million minimum) and 13U (S$50 million) with spending, hiring and local-investment conditions; no capital gains tax | No federal capital gains tax on private investments; cantonal wealth and income taxes; lump-sum taxation available to foreign residents who do not work in Switzerland, from about CHF 400,000 of deemed income in most cantons | No personal income or capital gains tax; 9% corporate tax on profits above AED 375,000 since 2023, with a 0% rate for qualifying free-zone income; single-family offices in DIFC and ADGM are typically outside the corporate tax net when they hold only family investments | State level: no income tax in South Dakota, Wyoming, Nevada or Florida; federal income tax on everything; no state estate tax in those states |
Substance | Minimum assets, two or three investment professionals, local business spending from S$200,000 a year, 10% or S$10 million invested locally | Office and staff expected; light formal thresholds; a licensed manager needed only where the office manages third-party money | Free-zone licence (a DIFC single-family office registers under the Family Arrangements Regulations 2023 without regulatory licensing), office, staff, an Emirates ID for the principal | A trust company or private trust company and administration in the state; South Dakota's private trust company regime starts at about US$200,000 of capital |
Privacy | Strong; no public beneficial-ownership register for private trusts; the ACRA register of controllers is not public | Strong, with automatic exchange of information with more than a hundred countries; the Swiss beneficial-ownership register due in 2026 is not public | Strong in the free zones; the UAE beneficial-ownership register is not public; automatic exchange applies | Strong for trusts in South Dakota and Delaware (sealed court records, no public trust registry); the Corporate Transparency Act now exempts domestic entities; FATCA and CRS do not apply to the US as a receiving jurisdiction, which is the quiet reason foreign families come |
Residence for the principal | Employment pass through the office; the Global Investor Programme for permanent residence with S$200 million under management, S$50 million in Singapore | Residence by lump-sum tax in most cantons; naturalisation after ten years | Golden visa (ten years) with AED 2 million of property or investment; no path to citizenship | EB-5 investor visa (US$800,000 in a targeted area); the catch is that a green card brings citizenship-based worldwide taxation and the estate tax |
Succession law | Common law; no estate duty; faraid for Muslims; foreign trusts recognised | Civil law with forced heirship, reduced in 2023 to half for descendants and none for parents; a foreign national may choose their national law; inheritance tax cantonal, with spouses and children exempt in most cantons | Sharia by default for Muslims; non-Muslims may register a will with the DIFC Wills Service or the ADGM registry and choose their national law; no inheritance tax | State law; perpetual trusts in South Dakota, Delaware, Nevada, Wyoming; federal estate tax for US persons at 40% above US$15 million, and on US-situs assets of non-residents above US$60,000 |
Best for | Asian and global families wanting a regulated hub with a residence route | European families wanting banking depth and a lump-sum tax deal | Families wanting no personal tax and a Gulf base, with a will registered | US families and long-horizon dynasty trusts; foreign families wanting a non-CRS jurisdiction, with careful avoidance of US-situs assets and US persons |
The runners-up
Hong Kong matches Singapore's incentive with its own family office concession (HK$240 million minimum) and fewer conditions, at the price of geopolitical caution. Jersey and Guernsey remain the trust jurisdictions of choice for British families, with no inheritance tax and deep trustee expertise. Luxembourg's private wealth management company suits European families who want to stay inside the EU. Italy's flat tax of €200,000 a year on foreign income has drawn London's leavers since 2025. Each is a real answer for a real family; none is the general answer.
Questions to ask before choosing
Where do the family members actually live and pay tax now, and where will the children? The office's jurisdiction changes nothing about a German-resident daughter's inheritance tax.
Which banks will open accounts for the structure, and how long will onboarding take?
What does the substance requirement cost in staff and rent, and does the family want to be there?
Which succession law applies to the principal's estate, and does the jurisdiction's law reach the family's assets elsewhere?
What happens to the incentive if the principal dies or the office changes hands? Singapore's incentive is granted to the fund, not the person, and continues if the conditions do; Switzerland's lump-sum deal ends with the person.
Is there a US person in the family, and if so, why are you not talking to a US attorney first?
The one asset no jurisdiction holds
Every base above keeps the money and its paperwork. The principal's judgement goes with the principal, unless it was recorded.
Family offices and their advisers: Make an enquiry
Frequently asked
Why do families base offices in Singapore?+
Tax exemption on qualifying fund income under 13O and 13U, a strong regulator and banks, privacy, and a residence route for the principal.
Is Dubai tax-free for a family office?+
No personal income or capital gains tax; a 9% corporate tax applies to businesses, with free-zone reliefs and an exemption in practice for single-family offices holding only family investments; substance is required.
Why South Dakota?+
No state income tax, perpetual trusts, sealed court records, a mature trust-company industry, and, for foreign families, a jurisdiction outside the Common Reporting Standard.
Does moving the office move the family's tax?+
No. Each family member is taxed where they live, and the United States taxes its citizens everywhere. The office's jurisdiction decides the fund's tax and the structure's law, not the heirs'.