Compliance, Legislative & Regulatory Standards

Trust Training Certificate (TTC) - Unit 11: International Tax - Part 1


This is Unit 11 of the training programme in pursuing the “Trust Training Certificate”.

It consists of two modules:
Module 17: Tax with regard to Trusts, Settlors & Beneficiaries
Module 18: Tax with regard to Assets

For the topics to cover, please refer to the content section below.


Tax with regard to Trusts, Settlors & Beneficiaries

Comparisons between UK, USA and China

- General application:
(a) Persons involved (settlor / founder / beneficiaries)
(b) Retention of assets and income without IEPS
(c) Transfer of assets to a trust / foundation
(d) Future income, benefits and assets derived from the structure
- The triggers for taxation
(a) Nationality
(b) Domicile
(c) Residence
(d) Source
- Domicile of origin
(a) Dependency
(b) Choice
(c) Deemed

Comparisons between Australia, Canada, France, Singapore, UK and USA

Residence of individuals and the tests:

- Quantitative (183 days)
- Quantitative (over more than one tax year)
- Qualitative (connections with the country)
- Reverse qualitative (connections with another country)
- Mixed qualitative and quantitative

Tax with regard to Assets

Comparisons between Hong Kong, Australia, Canada, UK and USA
- Nature – situs – recipient
- Tax and funds – issues for HK funds
- Tax and retirement schemes in HK
- Exemptions and reliefs:
(a) Nature of assets / property
(b) PPR
(c) Business property
(d) Agricultural property
- Recipient – surviving spouse - charities

Who should attend

The course is primarily targeted to those who would like to pursue “Trust Training Certificate” in order to apply for the Hong Kong Trustees’ Association Certified Trust Practitioner? designation.

It is also relevant to those who would like to gain a solid understanding of the course subject matter.

Speaker/Course Instructor

Stefano heads the tax and trusts practice at Deacons. He has a broad range of advisory and contentious tax experience, ranging from corporate taxation and group reconstructions to personal taxation and trusts and estate planning and management. He advises on all matters of Hong Kong and international tax law, including tax-efficient structuring and restructuring, and tax appeals before the Board of Review and the higher courts. His experience includes cross-border tax planning and Double Taxation Treaty driven tax structuring. Stefano further advises on all areas of Hong Kong and international trusts, estate planning, and charities, including the drafting of trusts instruments, restructuring of trusts structures, and trusts dispute resolution.


Date & Time
Tuesday, 21 May 2019 (6:00PM - 9:00PM)
HKSI Institute Training Centre
Relevant Subject
Regulatory Compliance
SFC:3.00, PWMA:3.00