‘An alternative solution for holding the shares of a private company or some other high risk assets on trust is to customise the trustee, rather than the trust instrument. … An estate planning arrangement may be structured by the incorporation of a private trust company, sometimes also known as a dedicated trust company, i.e. a company expressly created to act as trustee in one or more connected settlements relating to a single individual, family, or business group. … For wealth management purposes, the incorporation of a bespoke trustee company is often envisaged when the size of the intended trust fund and its composition, as well as the family dynamics potentially at stake, may exceed the responsibilities that a professional trustee is prepared to undertake (or that its insurer is prepared to cover). This is quite likely to be the case with a controlling interest in a manufacturing business, property investments in various jurisdictions, art collections, aircraft, and other vessels, especially if a combination of many, if not all of these assets is contemplated under the estate planning requirements of a particular family. The management of any or all the assets above exceeds the skills of the average professional trustee. Furthermore, if the main rationale is estate planning at the family level, some crucial exercise of trustee discretion may be called for, requiring an understanding of family matters that an outside professional trustee is unlikely to have. … A PTC, by its nature, does not offer its services to the general public. Accordingly, licensing and regulatory requirements that apply to professional trust service providers in most offshore jurisdictions are typically reduced in the case of a PTC.’ (International Trust Laws, by Paolo Panico).
Gregson v. HAE Trustees Ltd [2008] provides an English example of a company incorporated to act as trustee of family trusts following incorporation as a company limited by guarantee without a share capital. This involved bespoke drafting of the objects clause and articles. In principle, a trust deed can contain an express power to appoint a foreign trustee, and a trust corporation can be appointed as a sole trustee. In structuring a PTC the following issues need to be addressed:
·       Corporate governance at the PTC level, with the involvement of the trust beneficiaries and family members in general.
·       Licensing requirements, i.e. the choice of the jurisdiction of incorporation for the PTC.
·       The overlying holding structure for the shares of the PTC.

An interesting but rarely used concept is to use a foundation as a PTC as there can never be a shareholder, which is one drawback of a traditional PTC. If the foundation is incorporated in a traditional civil law jurisdiction then there is likely to be no licensing requirement for the foundation to act as a trustee.