Offshore Structuring & International Tax Planning

Multi-Jurisdiction Structures
for Tax Efficiency & Asset Protection

Offshore structuring is legal tax planning — designing a compliant multi-entity structure that uses the interaction between different jurisdictions' tax laws, treaties and corporate regimes to reduce the overall tax burden, protect assets and create operational flexibility. CompanyVista designs, forms and maintains structures across 50+ jurisdictions. Substance-compliant. BEPS-aware.

🏛️ Holding Company Structures 💡 IP Holding & Royalty Structures 🛒 E-Commerce & SaaS Structures 💼 Founder Relocation Structures 🌍 50+ Jurisdictions ⚖️ BEPS-Compliant · Substance-First
50+
Jurisdictions — entity formation
Legal
Tax planning — not evasion. Fully disclosed.
Substance
BEPS-compliant — substance non-negotiable
End-to-end
Design · Form · Comply · Maintain
Discuss My Structure → View Structure Types ↓
✅ Offshore Structuring Is Legal
Offshore structuring is legal tax planning — using the law as it stands. It is distinct from tax evasion (illegal concealment of income or assets). CompanyVista only advises on fully disclosed, compliant structures that can withstand tax authority scrutiny.
⚠️ Substance Is Non-Negotiable
Post-BEPS, simply incorporating in a low-tax jurisdiction is not sufficient. Genuine economic substance — real directors, real activity, real decisions made in the jurisdiction — is required. Letterbox structures will be challenged and dismantled by tax authorities.
📡 CRS — No Hiding From Tax Authorities
The Common Reporting Standard (CRS) enables automatic exchange of financial account information between 100+ countries. Your home country tax authority will know about your offshore accounts and company ownership. Structures must be legally compliant — not designed to conceal.
Structure Types

Common Offshore Structure Types —
What Each Achieves

🏛️
Holding Company Structure
Most Common
A parent holding company owns shares in one or more operating subsidiaries. Dividends, royalties and capital gains flow upward to the holding company. The holding jurisdiction is chosen for favourable dividend treatment (participation exemption), capital gains exemption and treaty access to reduce withholding taxes on inter-company payments.

How it works: Operating subsidiary earns income → pays dividend to holding company → dividend exempt or taxed at low rate under treaty → holding company retains or distributes at favourable rates. Capital gains on sale of subsidiaries may be exempt at holding level (Netherlands, Singapore, HK participation exemption equivalents).
Popular holding jurisdictions:
Netherlands — participation exemption Singapore — one-tier, no WHT Hong Kong — no CGT, territorial UAE — 0% qualifying Ireland — 12.5% + EU access Luxembourg — EU holding BVI/Cayman — zero tax, no treaties
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IP Holding Structure
High Value — Requires Substance
Intellectual property — software, patents, trademarks, copyrights — is held in a jurisdiction with a favourable IP regime (patent box / innovation box). The IP holding company licenses the IP to operating companies in other countries, receiving royalty payments taxed at significantly reduced rates.

Post-BEPS substance requirement: The IP must genuinely be developed, enhanced, maintained and exploited in the IP holding jurisdiction. Pure royalty-routing without substance will be challenged. The OECD nexus approach requires that IP box benefits correlate with actual R&D expenditure in that jurisdiction.
IP box regimes (effective rates):
Netherlands — 9% innovation box Ireland — 6.25% KDB Luxembourg — ~3.2% IP box Cyprus — 2.5% IP box UK — 10% patent box Malta — 80% deduction Singapore — IDI incentive
🛒
International Trading Company
E-Commerce · Import / Export · Distribution
An intermediate trading company in a low-tax jurisdiction purchases goods or services from manufacturers and sells to end customers — capturing the trading margin in a jurisdiction with a favourable corporate tax rate. Commonly used by e-commerce businesses, import/export companies and distribution businesses.

Transfer pricing critical: The trading company's margin must be priced at arm's length — the split of profit between the trading company and the manufacturer/operating entity must reflect genuine value creation. Thin capitalisation and economic substance rules apply.
Trading company jurisdictions:
Singapore — 17% (effective lower) Hong Kong — 8.25%/16.5% territorial Georgia — 15% on distributions Estonia — 0% retained profits UAE FZ — 0% qualifying income
🗄️
Offshore Trust & Foundation
Asset Protection · Succession Planning
Assets — shares, property, investments, business interests — are placed in a trust or foundation structure in an offshore jurisdiction. The trust holds assets for the benefit of named beneficiaries. Achieves asset protection from creditors, estate planning across multiple jurisdictions, privacy of ownership and inter-generational succession.

Specialist legal required: Trust and foundation structures are complex legal instruments. CompanyVista provides advisory and coordinates with specialist trust lawyers in the relevant jurisdiction — BVI, Cayman, Jersey, Guernsey, Isle of Man, Liechtenstein and others. Not suitable for undisclosed assets or tax evasion.
Common trust jurisdictions:
BVI Cayman Islands Jersey Guernsey Isle of Man Cook Islands Liechtenstein
Holding Company Jurisdictions

Choosing the Right
Holding Jurisdiction

The optimal holding jurisdiction depends on the countries of the operating subsidiaries, treaty requirements, the nature of income (dividends, royalties, capital gains) and the residency of ultimate shareholders. CompanyVista maps these factors during the structuring consultation.

Jurisdiction
Key Feature
Detail
🇳🇱 Netherlands
Participation exemption
Dividends and capital gains from qualifying subsidiaries fully exempt. Extensive treaty network. OECD compliant.
🇸🇬 Singapore
One-tier tax / no WHT
No withholding tax on dividends. One-tier tax system. Extensive treaty network.
🇭🇰 Hong Kong
0% CGT / territorial
No capital gains tax. No withholding tax on dividends. Territorial tax — offshore profits potentially exempt.
🇦🇪 UAE (DIFC/ADGM)
0% qualifying income
0% corporate tax on qualifying income. No withholding tax. Growing treaty network.
🇮🇪 Ireland
12.5% + EU access
12.5% corporate rate. EU parent-subsidiary directive. Participation exemption on qualifying dividends.
🇱🇺 Luxembourg
Participation exemption
EU member. Participation exemption. Extensive treaty network. Popular for EU fund and holding structures.
🇻🇬 BVI / Cayman
0% — no treaties
Zero corporate tax. No public register. No treaty access — used above operating companies, not for treaty benefits.
⚠️
Treaty access requires substance. BVI and Cayman companies are zero-tax but have no double tax treaty network — they cannot access treaty-reduced withholding tax rates on dividends, interest or royalties paid from treaty countries. To access treaties, the holding company must be in a treaty jurisdiction (Netherlands, Singapore, HK, Ireland) and have genuine economic substance there. This is a critical planning point — CompanyVista explains the implications during the structuring consultation.
Real-World Use Cases

Structures for
Common Business Situations

🛒
E-Commerce / Amazon Seller
Global Marketplace Seller — Multi-Jurisdiction Sales
US LLC (Amazon.com) + UK LTD (Amazon.co.uk) + Singapore Pte Ltd (APAC) → Singapore or HK Holding Company
Operations in each marketplace jurisdiction for local VAT/GST compliance and Amazon Brand Registry. Profits consolidate at Singapore or HK holding level — low effective corporate tax rate, one-tier dividend system, strong banking. Regional banking and payment processing from Singapore or HK. Trademark registered in each jurisdiction through the holding company.
💻
SaaS / Digital Product
Global Subscribers, Multiple Revenue Currencies
Estonia OÜ (EU customers — 0% retained profits) + UAE FZ (MENA/global — 0% qualifying) + US LLC (US customers) → BVI or Cayman Holding (exit vehicle)
Revenue collected in each region with minimal corporate tax drag on retained profits. IP (software) developed and held in Estonia or Ireland (IP box). BVI or Cayman holding company above the structure for clean exit — preferred by investors, easy share transfers. Annual compliance managed by CompanyVista across all four entities.
💡
IP-Rich Business
Software, Patents or Trademarks with Global Licensing
IP developed and held in Netherlands or Ireland → IP holding company licenses to operating companies → Royalties taxed at 9% (NL) or 6.25% (IE) effective rate
Operating companies in each country pay royalties to the IP holding company — reducing taxable profit in high-tax countries. Royalties taxed at favourable IP box rate at holding level. Requires genuine R&D activity in the IP jurisdiction — not a letterbox. Transfer pricing documentation required for all royalty arrangements. Significant effective rate reduction vs standard corporate rate in operating jurisdictions.
💼
Founder Relocation
Relocating from UK / India to UAE for Tax Optimisation
UAE free zone company → acquire existing trading company shares via UAE holding → UAE investor/Golden Visa → exit UK or India tax residency properly
UAE has no personal income tax, no capital gains tax, no dividend tax and no wealth tax. Founder relocates to UAE, obtains investor or Golden Visa, and restructures business ownership through UAE holding company. Critical: proper exit from home country tax residency is non-negotiable — UK has an extensive exit tax regime and India has deemed residency rules. Specialist tax advice in home country required before any restructuring.
Economic Substance — Non-Negotiable

Substance Is the Foundation
of Every Legitimate Offshore Structure

Following the OECD BEPS (Base Erosion and Profit Shifting) action plan, simply incorporating in a low-tax jurisdiction is no longer sufficient to claim tax benefits there. Every legitimate offshore structure must have genuine economic substance in the jurisdiction where profits are booked. CompanyVista designs structures with substance from the outset — not as an afterthought.

✅ What Counts as Economic Substance
  • ✓Physical office or registered address used for genuine business activity
  • ✓Employees or resident directors making genuine business decisions in the jurisdiction
  • ✓Board meetings held in the jurisdiction with board members physically present
  • ✓Management and control exercised in the jurisdiction — not from the owner's home country
  • ✓Core income-generating activities conducted or directed from the jurisdiction
  • ✓Adequate operating expenditure in the jurisdiction proportionate to the income booked
✗ What Is No Longer Sufficient (Post-BEPS)
  • ✗Incorporating in a low-tax jurisdiction with no actual activity there
  • ✗Letterbox company — registered address only, no employees, no decisions made locally
  • ✗IP box benefits without genuine R&D activity in the jurisdiction (OECD nexus approach)
  • ✗Management and control exercised from the owner's home country — triggering "managed and controlled" residency in the home country
  • ✗Profits booked offshore while all economic activity is in a high-tax country
  • ✗Artificially routed royalty or management fee payments without genuine services rendered
⚠️ Economic Substance Acts — BVI, Cayman & Bahamas

BVI (Economic Substance Act 2018), Cayman Islands (International Tax Co-operation (Economic Substance) Act 2018) and Bahamas (Commercial Entities (Substance Requirements) Act 2018) have all enacted mandatory economic substance legislation. Companies incorporated in these jurisdictions that conduct "relevant activities" (banking, insurance, fund management, finance & leasing, headquarters, intellectual property, distribution & service centres, holding company activities) must demonstrate adequate economic substance or face significant penalties and automatic reporting to the relevant tax authority in the jurisdiction of the ultimate beneficial owner. CompanyVista advises on substance requirements for every BVI and Cayman entity in a structure.

📡
CRS — Common Reporting Standard. 100+ countries automatically exchange financial account information. Your home country tax authority already knows about your offshore bank accounts, company ownership and financial balances. Offshore structures must be legally compliant and properly disclosed to your home country tax authority — they are not and cannot be a concealment mechanism. CompanyVista only advises on structures that are fully disclosed and legally defensible.
What's Included

CompanyVista Offshore Structuring —
From Design to Ongoing Compliance

🗺️
Structure Design Consultation
CompanyVista maps your business model, revenue flows, IP ownership, current jurisdictions, ultimate shareholder residency and objectives — and designs the optimal multi-entity structure. The design considers substance requirements, treaty access, CRS implications and ongoing compliance cost. A written structure diagram and rationale is provided before any entity is formed.
🏢
Entity Formation in All Jurisdictions
CompanyVista forms all entities in the structure — BVI holding, Singapore or HK operating company, UAE free zone entity, US LLC, Estonian OÜ, UK LTD and any other required. All incorporation, registered agent, registered office and nominee director (where required) arranged as part of the same engagement. One team, one timeline, no coordination between separate formation agents.
📑
Shareholder Agreements & Inter-Company Contracts
Inter-company agreements — shareholder agreements, IP licence agreements, management service agreements, loan agreements — are required to formalise the structure and establish the contractual basis for inter-company payments. CompanyVista coordinates document preparation with qualified lawyers in the relevant jurisdiction.
🏦
Banking Coordination Across the Structure
Each entity in the structure requires appropriate banking — traditional bank or fintech. CompanyVista coordinates banking for all entities simultaneously — introductions, KYC document preparation, account opening coordination. Ensures each entity has access to appropriate payment infrastructure before the structure is operational.
📊
Accounting & Bookkeeping — All Entities
Each entity in the structure requires separate bookkeeping and annual accounts. CompanyVista provides accounting for all entities through one team — maintaining consistent inter-company transaction records, ensuring transfer pricing positions are supported by the books, and producing consolidated or entity-level management accounts as required.
📋
Annual Compliance — All Jurisdictions
Every entity in the structure has annual compliance obligations — annual return, registered office renewal, registered agent fee, annual government fee, economic substance reporting. CompanyVista tracks all deadlines across all entities in one compliance calendar — zero missed deadlines. BVI economic substance filings, Cayman annual fees, Singapore ACRA annual returns, HK NAR1 — all managed.
📃
Tax Returns — All Entities
Corporate tax returns prepared and filed for every entity in the structure — Singapore Form C-S, HK Profits Tax Return, US Form 1065 or 1120, UK CT600, Estonian quarterly declarations, UAE FTA return. Consistent with the annual accounts. Transfer pricing positions documented where required.
🤝
Specialist Referrals Where Required
CompanyVista is not a law firm. For formal tax opinions, transfer pricing studies, legal opinions on structure validity, trust deed preparation and complex cross-border tax advice, CompanyVista coordinates with trusted specialist tax lawyers and Big 4 tax advisors in the relevant jurisdictions. We manage the relationship — you get one point of contact for the full engagement.
How It Works

From Business Objectives
to Operational Structure

1

Business & Tax Position Assessment

CompanyVista reviews your business model, revenue sources and geography, IP ownership, current legal structure, ultimate shareholder residency and home country tax position. This baseline determines what the structure needs to achieve — tax efficiency, asset protection, operational flexibility, exit readiness or a combination. Free initial consultation.

⏱ Free — typically 45–60 minutes
2

Structure Design & Written Proposal

CompanyVista designs the optimal multi-entity structure — identifying the holding jurisdiction, operating entities, IP holding vehicle (if applicable), inter-company flow of dividends/royalties/management fees, treaty positions and substance requirements. A written structure diagram with full rationale, estimated tax savings, substance requirements and ongoing compliance cost is provided before any commitment. Where formal tax opinions are required, specialist tax advisors are identified.

⏱ Written proposal within 5–7 business days
3

Written Quote — All Costs Confirmed

A complete written quote covers: formation fees for each entity (govt fees at exact cost, CV professional fee), registered office and agent annual fees, nominee director (where required), banking introduction fees, annual compliance fees per entity, accounting retainer per entity and tax return fees per entity. Total ongoing annual cost of the structure is stated clearly — structures that cost more than they save are not recommended.

⏱ Written quote within 24 hours of structure design approval
4

Entity Formation — All Jurisdictions

CompanyVista forms all entities in the structure simultaneously where possible — BVI, Singapore, HK, UAE, Estonia, US, UK and others. Shareholder agreements, inter-company agreements (IP licence, management service agreement) prepared in coordination with specialist lawyers. Company secretarial, registered office and registered agent established in every jurisdiction. All entities formed within one coordinated engagement.

⏱ 2–8 weeks depending on jurisdictions — most done in parallel
5

Banking & Operations Activated

Banking arranged for each entity — traditional bank or fintech depending on jurisdiction and use case. KYC documentation prepared and coordinated for all entities simultaneously. Payment flows between entities (royalty payments, dividends, management fees) established and tested. Accounting software configured for each entity with the correct chart of accounts and inter-company transaction codes.

⏱ Banking: 2–6 weeks per jurisdiction
6

Ongoing Compliance — All Entities, One Team

CompanyVista maintains annual compliance for every entity in the structure — annual returns, registered office renewals, government fees, economic substance filings (BVI/Cayman), accounting, tax returns and nominee director renewals. One compliance calendar tracks every deadline across all entities. One invoice covers all entities. Annual review of the structure to ensure it remains optimal as the business grows and regulations evolve.

⏱ Ongoing — annual compliance managed proactively
Why CompanyVista

Why Choose CompanyVista
for Offshore Structuring?

🗺️

End-to-End — Design to Compliance

CompanyVista handles the full lifecycle — structure design, entity formation in all jurisdictions, banking, accounting, annual compliance and tax returns. No coordinating between a BVI agent, a Singapore accountant, an HK compliance firm and a US tax agent. One team manages the entire structure — with one consolidated compliance calendar and one annual invoice.

⚖️

Substance-First Design

CompanyVista designs substance into every structure from day one — not as an afterthought. Every entity's substance requirements are identified upfront, nominee directors provided where required, registered offices in real addresses, and board meeting documentation maintained. Structures that cannot demonstrate genuine substance are not recommended — they create more risk than they eliminate.

💡

Honest About What Works

Some structures that were effective 10 years ago are no longer viable post-BEPS. CompanyVista does not recommend letterbox structures, treaty shopping arrangements without substance or royalty stripping schemes. We recommend structures that are legally defensible today and sustainable — not ones that may be unwound by a tax authority tomorrow.

🤝

Specialist Network — Tax Lawyers & Big 4

For formal tax opinions, transfer pricing studies and complex cross-border legal advice, CompanyVista works with trusted specialist tax lawyers and Big 4 advisors in the relevant jurisdictions. We coordinate the engagement and manage the relationship — you work with one team rather than coordinating multiple specialist firms directly.

💰

Total Cost Transparency

Offshore structures have significant ongoing costs — registered office, registered agent, nominee director, annual government fees, accounting, tax returns. CompanyVista provides a complete annual cost projection for the full structure before any entity is formed. Structures that cost more in ongoing compliance than they save in tax are not recommended — the numbers must work.

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CRS-Aware — Fully Disclosed

Every structure CompanyVista designs is built on the assumption that the beneficial owner's home country tax authority will receive full information under CRS — because they will. Offshore structures in 2025 work through legal tax efficiency, not concealment. If a structure only works if hidden from your tax authority, it is not a structure CompanyVista will advise on.

Frequently Asked Questions

Offshore Structuring —
Questions Answered

Is offshore structuring legal? +
Yes — offshore structuring is legal tax planning that uses the interaction between different countries' tax laws, treaties and corporate regimes to reduce overall tax burden in a compliant manner. It is completely distinct from tax evasion, which involves illegal concealment of income or assets. Legal offshore structures are fully disclosed to home country tax authorities, properly documented, comply with economic substance requirements and use genuine business rationale. CompanyVista only advises on structures that are legal, fully disclosed and sustainable under scrutiny from tax authorities.
What is economic substance and why is it required? +
Economic substance is the genuine presence and activity of a company in the jurisdiction where it is incorporated and where it books profits. Following the OECD BEPS (Base Erosion and Profit Shifting) action plan, simply incorporating in a low-tax jurisdiction is no longer sufficient. The company must demonstrate: real employees or resident directors making business decisions in the jurisdiction, board meetings held locally, core income-generating activities conducted from the jurisdiction, and adequate operating expenditure proportionate to the income booked. BVI, Cayman and Bahamas have all enacted Economic Substance Acts. IP box benefits in the Netherlands, Ireland and Cyprus require genuine R&D activity under the OECD nexus approach.
What is CRS and does it affect my offshore company? +
The Common Reporting Standard (CRS) is an OECD framework for automatic exchange of financial account information between 100+ participating countries. Under CRS, financial institutions automatically report account information — account holder identity, account balance and income — to their local tax authority, which then shares it with the tax authority in the account holder's country of residence. This means your home country tax authority already knows about your offshore bank accounts and company ownership. Offshore structures cannot be used to conceal income or assets — they must be legally compliant and properly disclosed. CRS has made the concealment model of offshore structures obsolete; legal efficiency structures remain fully viable.
Which jurisdiction is best for a holding company? +
The optimal holding jurisdiction depends on specific facts — the countries of the operating subsidiaries, the residency of ultimate shareholders, the nature of income flows (dividends, royalties, capital gains) and treaty requirements. Singapore offers a one-tier tax system with no withholding tax on dividends and an extensive treaty network — ideal for APAC-focused structures. Hong Kong offers no capital gains tax, no withholding tax and territorial taxation. The Netherlands offers a participation exemption on qualifying dividends and capital gains — ideal for EU-facing structures. BVI and Cayman offer zero tax but no treaty network — used as holding vehicles above treaty holding companies, not for treaty access directly. CompanyVista maps the optimal jurisdiction for each client's specific structure during the consultation.
What is an IP holding structure and which jurisdictions offer the best IP box regimes? +
An IP holding structure places intellectual property in a jurisdiction with a favourable IP regime (patent box or innovation box), where royalty income is taxed at a significantly reduced rate. Key regimes: Netherlands Innovation Box (9% effective rate on self-developed IP income), Ireland Knowledge Development Box (6.25% effective rate), Luxembourg IP Box (~3.2% effective), Cyprus IP Box (2.5% effective), UK Patent Box (10% on qualifying patent income), Malta (80% deduction). Post-BEPS, all these regimes require genuine economic substance — the IP must be developed, enhanced, maintained and exploited in the jurisdiction. The OECD nexus approach requires that tax benefits correlate with actual R&D expenditure in the jurisdiction. Pure royalty-routing without substance is no longer effective.
How does a BVI holding company work above an operating company? +
A BVI company is commonly used as a holding company above one or more operating companies in higher-tax jurisdictions. The BVI company holds the shares of the operating subsidiaries. When the operating company pays a dividend to the BVI holding company, the dividend may be subject to withholding tax in the operating company's country — the rate depends on whether there is a tax treaty between that country and BVI. BVI has no tax treaties, so treaty rates do not apply; standard withholding tax rates apply instead. The BVI company pays no tax on dividends received. It is therefore most efficient as a holding layer above treaty holding companies (e.g. BVI → Singapore → operating companies) rather than directly above operating companies in treaty countries.
What is transfer pricing and why does it matter for my structure? +
Transfer pricing refers to the prices at which transactions occur between related companies in different countries — royalty payments for IP use, management fees, intercompany loans, intragroup sales of goods or services. Tax authorities require that these prices be set at arm's length — as if the parties were independent, unrelated companies. If the pricing is not at arm's length, tax authorities in the higher-tax jurisdiction will adjust the taxable profit upward — triggering additional tax, penalties and interest. For any structure involving inter-company payments (royalties, management fees, dividends), transfer pricing documentation is required in most jurisdictions. CompanyVista identifies transfer pricing documentation requirements and coordinates preparation with specialist tax advisors.
Can I move my existing company into an offshore holding structure? +
Yes — restructuring an existing company into a holding structure is possible but more complex than building a structure from scratch. Options include: share swap (existing shareholders exchange shares in the operating company for shares in a new holding company — may trigger capital gains tax in some jurisdictions), a dividend reinvestment into a new holding company, or a legal merger/demerger. The tax implications of the restructuring itself — particularly capital gains tax on the transfer of shares — must be carefully assessed before any restructuring is implemented. This is covered under CompanyVista's Restructuring & Flip service, which should be consulted for existing companies. CompanyVista always models the tax cost of the restructuring against the long-term benefit before recommending a reorganisation.
What ongoing compliance is required for an offshore structure? +
Every entity in the structure has its own annual compliance obligations — annual return, registered office renewal, registered agent fee, annual government fee, economic substance reporting (BVI/Cayman), accounting, tax return and nominee director renewal. For a typical three-entity structure (BVI holding + Singapore operating + UK operating), the annual compliance calendar covers: BVI annual fee (31 May), BVI economic substance report, Singapore ACRA annual return, Singapore Form C-S tax return, UK CS01 confirmation statement, UK CT600 corporation tax return, UK annual accounts filing. CompanyVista tracks all of these in one compliance calendar with 60-day advance reminders — ensuring nothing lapses across any entity in the structure.
Does CompanyVista provide formal tax opinions on offshore structures? +
No — CompanyVista is not a law firm and does not provide formal legal or tax opinions. We provide informational tax planning advisory and structure design. Formal tax opinions, transfer pricing reports, legal opinions on structure validity and advice on aggressive tax planning positions require qualified tax lawyers and specialist tax advisors (Big 4 or specialist boutiques) in the relevant jurisdictions. CompanyVista coordinates with our network of trusted specialist firms when formal opinions are required — managing the engagement and acting as your central point of contact. This ensures you get the specialist opinion you need without managing multiple advisory relationships independently.
Offshore Structuring

Design Your International Structure —
Free Consultation

CompanyVista designs, forms and maintains offshore and international structures across 50+ jurisdictions. Substance-compliant. BEPS-aware. CRS-transparent. Legal tax efficiency — not concealment. Free initial consultation, written proposal and complete cost projection before any commitment.

Discuss My Structure → WhatsApp Us Now
✓ 50+ jurisdictions — one team ✓ Substance-compliant design ✓ BEPS-aware — legally defensible ✓ Written proposal before commitment ✓ Complete cost projection upfront ✓ End-to-end — design to compliance

Offshore Structuring & International Tax Planning — 2025 Guide

CompanyVista designs and implements multi-jurisdiction corporate structures for international businesses, e-commerce sellers, SaaS companies, IP-rich businesses and relocating founders. Core structure types: holding company structures (Netherlands participation exemption, Singapore one-tier system, Hong Kong no capital gains tax, UAE 0% qualifying income, Ireland 12.5% + EU parent-subsidiary directive, Luxembourg participation exemption, BVI/Cayman zero tax without treaty access); IP holding structures (Netherlands Innovation Box 9%, Ireland Knowledge Development Box 6.25%, Cyprus IP Box 2.5%, UK Patent Box 10% — all requiring genuine economic substance post-BEPS); international trading companies (Singapore 17% with exemptions, HK territorial 8.25%/16.5%, Georgia 0% Virtual Zone, Estonia 0% retained profits, UAE FZ 0% qualifying); offshore trusts and foundations (BVI, Cayman, Jersey, Guernsey, Isle of Man, Liechtenstein) for asset protection and succession planning.

Economic substance is non-negotiable post-BEPS — BVI Economic Substance Act 2018, Cayman International Tax Co-operation (Economic Substance) Act 2018 and Bahamas Commercial Entities (Substance Requirements) Act 2018 require relevant activities to demonstrate genuine substance or face automatic reporting to the beneficial owner's home country tax authority. The Common Reporting Standard (CRS) enables automatic exchange of financial information between 100+ countries — offshore structures cannot conceal income or assets from home country tax authorities; they work through legal tax efficiency, full disclosure and genuine substance. Transfer pricing documentation is required for all inter-company payments — royalties, management fees, intragroup sales. CompanyVista is not a law firm — formal tax opinions, transfer pricing studies and legal opinions require qualified tax lawyers and specialist advisors.

offshore company structuring service international holding company structure IP holding company Netherlands Ireland BVI holding company structure Singapore holding company structure BEPS compliant offshore structure economic substance offshore company e-commerce offshore structure SaaS international tax structure founder relocation UAE tax structure

Offshore Structuring · 50+ Jurisdictions · Holding · IP · Trading · BEPS-compliant · Substance-first

Discuss My Structure →