However, the most significant development is the enactment in the Cayman Islands of their STAR Trust legislation. This law became effective in November 1997. Amongst other things it provided that a STAR Trust could be created for purposes or for persons or for both. There were other special features of the legislation. This talk follows what Philip Baker and Paul Maurice said in 1993.
Several jurisdictions present themselves as homes for trusts with treaty advantages.
In Cyprus, the International Trusts Law of 1992 provides a similar exemption, as does the Income Tax Act in Malta. In Mauritius, trustees of offshore trusts have the option of paying a small amount of tax and having the advantage of treaties or paying no tax and not getting treaty benefits. New Zealand gives its local trust companies a tax exemption for the income of settlements made by non-resident settlors. While it appears that there is a good deal of undiscovered scope for treaty shopping through trusts, some discretion is to be advised. A careful reading of the text of the relevant treaty is required in each case.