Jurisdiction Comparisons for Your Company

Why compare jurisdictions in pairs

After the first review of a task, two countries usually remain on the list, and the decision comes down to details: who registers the company, which reports it files, how beneficial owners are disclosed, what the bank will ask and how much maintenance costs over two years. Each comparison starts with a table of these parameters and ends with scenarios: which option is more often chosen for a holding company, trade, services or holding assets.

Which pairs are covered

Islands. The BVI against Belize, Seychelles and the Cayman Islands, and Panama against Nevis. Since 2 January 2025, BVI companies have filed beneficial ownership information with the registry through the VIRRGIN system, and the annual financial return goes to the agent within 9 months of the year end. The Cayman Islands are chosen above all for investment funds. Panama taxes only income from Panamanian sources, and in Nevis the annual renewal fee for an IBC or an LLC is USD 300.

Asia and the Middle East. Hong Kong taxes Hong Kong-sourced profit at 8.25% and 16.5%; Singapore charges 17% and requires a director who is ordinarily resident in the country. In the UAE, the 9% rate applies to profit above AED 375,000, and 0% in a free zone is available only to a qualifying company.

Europe and the US. Estonia against Cyprus, UK LTD against US LLC, and Delaware against Wyoming. A British LTD pays Corporation Tax at 19 to 25%. The income of a US LLC with one foreign owner is by default attributed to the owner, and the company files Form 5472 every year.

The whole model. A separate comparison covers the choice between a classic offshore company and a regular foreign company: CFC rules, the place of management, economic substance and the 15% global minimum tax for large groups.

How to use the comparisons

The figures in the tables apply at company level: state fees, tax rates and reporting deadlines. The agent's services, bookkeeping and the bank are calculated separately, so we put together the two-year budget for the specific structure. EU list status is given according to the EU Council conclusions of 9 October 2026: none of the jurisdictions compared is on the list of non-cooperative jurisdictions, and the BVI and Panama have entries in Annex II.

In every case, the owner's taxes are set by the country of the owner's residence, so the result for a pair is worth recalculating with CFC rules and dividend tax in mind. If no pair fits, start with the full list of countries in the catalogue of offshore jurisdictions and the guide to choosing a jurisdiction.

Jurisdiction comparisons

• BVI vs Belize: holdings and assets

  Two companies acts, the agent, beneficial owners and bookkeeping in one table, plus a holding scenario ahead of a future sale of a stake.

• BVI vs Seychelles for a holding company

  A holding company for investors or a small asset-holding structure: registers, the 10% beneficial owner threshold in Seychelles and banks' questions.

• Cayman Islands vs BVI: funds, SPVs and holdings

  A fund, an SPV or a family holding company: fund regulation by CIMA and under SIBA, reporting and scenarios for choosing between the two islands.

• Delaware vs Wyoming: LLC for a non-resident

  The fees and deadlines of the two states, the same federal forms and three typical scenarios: a start-up, a consultant and a team in a third state.

• Estonia vs Cyprus: profit and dividends

  Tax on distribution against a 15% rate, the contribution on dividends and the company's residence: how to calculate the full path of money to the owner.

• Hong Kong vs Singapore: directors and reporting

  A territorial tax and the FSIE regime against a 17% rate and a local director: who should trade through Hong Kong and who should build a team in Singapore.

• Offshore vs regular foreign company: which pays off

  When a classic offshore company pays off and when a regular taxed company is better: CFC rules, the place of management, substance and Pillar Two.

• Panama vs Nevis: trading and assets

  Panama's territorial tax and Law 526 against Nevis IBCs and LLCs: agents, beneficial owners, annual fees and the bank.

• UAE vs Singapore: free zones and rates

  The UAE federal tax and free zone conditions against Singapore's 17%: where the team should live and where to open an office.

• UK Ltd vs US LLC for non-residents

  Corporation Tax and Companies House against the tax classification of an LLC and Form 5472: what to choose for your clients and investor plans.