Corporate Services

The six jurisdictions side by side

The short version. Each jurisdiction has its own page with the detail behind these figures.

Fees are ours; government charges, audit and banking costs are separate and differ sharply. Status as at the Council revision of 17 February 2026.

How to choose

The common mistake is to start with the tax rate. The rate is the last question, not the first, because three others decide whether the structure can function at all.

First: where will the bank account open?

A company without an account solves nothing. Banks assess the beneficial owner — nationality, tax residence, source of funds, the geography of counterparties — not the certificate of incorporation. The same Seychelles IBC in two different pairs of hands clears compliance with entirely different probability. If an account is realistic only in the UAE, saving a few hundred dollars elsewhere buys you a company you cannot use.

Second: do you need to move?

If residence, schooling or a change of personal tax residence is part of the objective, the list shortens immediately. Real routes through a company exist in the UAE, Singapore and Cyprus. Hong Kong, Panama and the Seychelles offer none — and a Seychelles IBC is by law not permitted to carry on business locally, so it cannot even support a work permit.

Third: where are you tax resident?

The rate in the country of incorporation is half the picture. The other half is the law where you actually live. For an EU resident that means your Member State’s controlled foreign company rules, exit taxes and reporting duties. For an Indian resident it means the overseas investment framework, place of effective management and Schedule FA. Both are set out below.

Only then, the jurisdiction

Once those three are answered, the choice is usually down to one or two candidates and comparing rates finally makes sense. That is the point at which the table above becomes useful.

If you are resident in the European Union

Two things decide most of the analysis: whether the jurisdiction is on the EU list, and what your own Member State does about foreign companies. They are separate questions and the second one matters more.

The EU list, and what being on it costs

In the revision adopted by the Council on 17 February 2026, Panama is on Annex I — the blacklist. The UAE, Hong Kong, Singapore and the Seychelles are on neither annex; the Seychelles was removed from Annex II in that same revision. Cyprus cannot appear at all, because the list covers third countries only.

Listing is not symbolic. Member States committed from 2021 to apply at least one legislative defensive measure to Annex I jurisdictions — non-deductibility of costs, CFC inclusion, higher withholding tax, or restriction of the participation exemption — and most apply two or more. Separately, DAC6 hallmark C.1(b)(ii) makes a deductible cross-border payment to an associated enterprise in a listed jurisdiction reportable within 30 days with no main benefit test: it is reportable whether or not any tax advantage is sought.

Controlled foreign company rules are national, not European

The Anti-Tax Avoidance Directive sets a floor. Article 7 catches an entity where you hold more than 50% of votes, capital or profit entitlement and the tax it actually pays is below half of what your Member State would have charged. Each Member State then chose its own model and thresholds. There is no single European CFC rule.

On these tests the UAE at 9%, Panama on foreign income and a Seychelles IBC all fail comfortably; Singapore at 17% generally clears them, though start-up and partial exemptions can push the effective rate below 15% in the early years; Cyprus at 15% sits exactly on the German and Italian line. What differs for Cyprus is the defence: freedom of establishment and the EU abuse-of-law case law constrain what a Member State may do about a genuine structure, in a way that has no equivalent for a third country.

Leaving is a separate problem from arriving

• Germany — § 6 AStG imposes exit tax on shareholdings of 1% or more; § 2 AStG extends limited tax liability for ten years where a German national moves to a low-tax country and keeps substantial German interests.
• Italy — Article 2(2-bis) TUIR presumes a citizen who deregisters and moves to a State on the decree of 4 May 1999 remains Italian tax resident. The UAE, Hong Kong, Singapore, Panama and the Seychelles are all on that list; Cyprus was removed in 2010.
• Spain — Article 8.2 LIRPF keeps nationals taxable for the year of the move and four more, but only for destinations on the Spanish list. None of our six is currently on it: the Seychelles came off on 28 June 2026.
• Portugal — Portaria 150/2004, as amended in 2025, still lists the UAE, Panama and the Seychelles; Hong Kong was removed.

If you are resident in India

For an Indian resident this is an exchange-control transaction before it is a tax question. The Foreign Exchange Management (Overseas Investment) Rules and Regulations 2022 have applied since 22 August 2022. Get the sequence wrong and the bank simply cannot remit.

What a resident individual may and may not do

• Invest within the overall Liberalised Remittance Scheme limit of USD 250,000 per financial year. Gifts and inheritances are not counted against it.
• File Form FC and obtain a Unique Identification Number before any remittance. The bank cannot remit without it, and a UIN is not an approval.
• Route everything through one designated authorised dealer bank.
• File an Annual Performance Report by 31 December for each foreign entity, on audited accounts or certified by a chartered accountant.
• No investment into financial services activity — which rules out much of what Singapore and Hong Kong are known for.
• No real estate activity — buying and selling property or trading development rights, for any person resident in India.
• No control in a foreign entity that has a subsidiary or step-down subsidiary — the provision that blocks the classic personal holding company above operating subsidiaries.

Tax is collected at source at 20% on remittances above ₹10 lakh in aggregate in the financial year for investment purposes. The threshold rose from ₹7 lakh on 1 April 2025 and the Finance Act 2026 left the 20% rate untouched even while cutting education and medical remittances to 2%.

Treaties make the difference between these six

Cyprus was notified as a jurisdictional area under section 94A in November 2013. That notification was rescinded in December 2016 with retrospective effect from 1 November 2013 — material saying otherwise is a decade out of date.

Where your company is tax resident

The Income-tax Act, 2025 came into force on 1 April 2026 and replaced the 1961 Act, so anything written in the old section numbering is now wrong for the current tax year. Under section 6(10), a foreign company whose key management and commercial decisions are in substance made in India is Indian tax resident on its worldwide income. Guidance under Circular No. 6 of 2017 and the ₹50 crore carve-out in Circular No. 8 of 2017 have not, to our knowledge, been formally re-issued under the new Act; we treat the carve-out as applicable in practice but not settled.

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