For an international family, the Gelephu Mindfulness City offers a 0% personal rate for non-citizens until the end of 2030, a 15% corporate rate, and a family-office exemption written into the statute. Getting the structure right means knowing how those fit together. Basnet Law Pte. Ltd. is the first incorporated law firm in GMC. We advise international principals and their advisers on establishing family holding structures, trusts and single-family offices in the Gelephu Mindfulness City. This page explains the rules as they stand and how we put a family structure in place.
Our legal advisory
- Advising on structuring family investment holding companies around the share disposal exemption and the 15% corporate rate.
- Personal tax planning around the 0% rate for non-citizen individuals to 31 December 2030.
- Advising on the family-owned investment holding company exemption.
- Trust and estate planning under the Income Tax Act 2025's trust income rules.
- Deciding whether the family office needs a licence for Managing Assets under the Financial Services Act 2025 or falls within the bare trustee and group exclusions.
- Residency and work passes for principals and staff, and the resident-director requirement under the Companies Act 2025.
- Privacy: keeping residential addresses out of public inspection on the company register.
How GMC private client law works, in plain terms
GMC's personal tax position is set by the Income Tax Act 2025. An individual who is not a citizen of Bhutan, "whether resident in GMC or not", is taxed at 0% on chargeable income derived on or before 31 December 2030. Companies pay 15% on chargeable income. Trustees and executors are also charged at 15%, but where a beneficiary is entitled to a share of trust income the Comptroller may charge that share at a lower rate or not at all. A resident beneficiary's share of trust income is exempt if it would have been exempt had the beneficiary derived it directly.
The Act exempts "all relevant income of an eligible family-owned investment holding company", meaning a company whose shareholders are related in the way regulations prescribe and whose operation consists wholly or mainly of holding or making investments. The exemptions for foreign trusts administered by a GMC trustee company and for locally-administered trusts are similar. We advise on structures that use these exemptions alongside the general rules.
On regulation, managing assets on a discretionary basis for another person is a specified activity under the Financial Services Act 2025. A bare trustee acting on the beneficiary's instructions and not holding out a dealing service is excluded, as are transactions between members of the same group. Whether a single-family office needs a licence turns on the "by way of business" test and on how the family's entities are organised.
Who this is for
- International families considering GMC as a holding and residence base.
- Principals relocating before the 31 December 2030 tax window closes.
- Single-family offices deciding whether to be licensed or to sit within the exclusions.
- Trustees and private banks with clients moving assets to GMC.
How a legal advisory engagement runs
- Objectives review. Residence, succession, asset protection and reporting goals, agreed with the principal before anything is designed.
- Structure design. Holding company, trust or partnership, tested against the trust income rules, the share disposal exemption and the rates, and against the trust and family-office exemptions.
- Regulatory analysis. A written view on whether Managing Assets is engaged and which exclusions apply.
- Implementation. Advice on incorporation, the constitution, the resident director, and work passes for family members and staff.
- Ongoing stewardship. We keep the structure aligned with the regulations that define an eligible family-owned investment holding company, so the exemption is preserved year on year.
Frequently asked questions
How does the GMC family office tax exemption work?
The Act exempts the relevant income of an eligible family-owned investment holding company. Income outside the exemption is taxed under the general rules, including the 15% rate and the share disposal exemption where its conditions are met. We design the structure so both work together.
Will a family member pay personal income tax in GMC?
A family member who is not a citizen of Bhutan pays 0% on chargeable income derived on or before 31 December 2030. We confirm the position for each family member and advise on the filings.
Does a single-family office need a GFSO licence?
Only if it carries on a specified activity such as Managing Assets by way of business in GMC. Family-internal structures may fall within the group exclusion or the trustee exclusion. We provide the analysis in writing.
Can I keep my home address off the public register?
Yes. Under the Companies Act 2025 the Registrar must exclude the residential address of a director, chief executive officer or secretary from public inspection where a contact address is available. We advise on the contact address as part of incorporation.
Contact
Basnet Law Pte. Ltd. is the first law firm incorporated in the Gelephu Mindfulness City.
You may contact Basnet Law at basnet@basnetgmc.com or office@basnetgmc.com for any legal queries related to GMC.
