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Offshore Structures for IT, Trading and Holding Companies

An offshore business structure is a company or group of companies in one or more jurisdictions, set up for a specific activity: IT services, trading, asset holding or a holding company. It is selected based on the clients’ countries, the owner’s tax residency, banks’ requirements and economic substance rules. Offshora builds such a structure for your model and calculates its running costs.

Model of three kinds of business on one stand: a warehouse with crates at a loading ramp, a glass office studio and a quay with a cargo crane
IT, trading, holding companies, assets

Offshore company for IT, consulting and service exports

When selling services to foreign clients, counterparties’ trust, payment infrastructure and clear reporting matter. A common choice is a UK Ltd: Corporation Tax at 25%, a 19% rate for profits up to £50,000, and reporting to Companies House. For teams with clients in Asia, Singapore and Hong Kong are considered. Industry reviews for SaaS, e-commerce and crypto projects are in the Business solutions section.

For an IT agency or a SaaS business, we decide separately where the rights to the code and the trademark will sit, who signs contracts with clients and which payment system the revenue goes through. These questions are covered in the articles a structure for an IT agency and a legal entity for SaaS.

Consultants and freelancers

A specialist working with foreign clients alone or with a small team usually needs only a simple structure. What matters most is that the clients’ payment services accept the company and that the income is easy to declare in the country of residence. The options are compared in the article an offshore structure for consultants and freelancers.

International trade

A trading company needs an account with foreign currency settlements, contracts with suppliers and buyers, and a clear geography of supplies. Hong Kong applies the territorial basis of taxation: profits tax of 8.25% on the first HK$2 million and 16.5% above that amount is paid on Hong Kong-sourced profits. Since 2023 it has had a foreign-sourced income exemption (FSIE) regime, expanded in 2024: for members of multinational groups, certain types of foreign income received in Hong Kong are taxed if the exemption conditions are not met. In the BVI, distribution and service centers are on the list of activities in the economic substance law. A step-by-step breakdown is in the guide a company for international trade.

Online store and e-commerce

For online sales, three things decide the setup together: the company’s country, the marketplace or acquirer that will accept it, and the VAT rules in the buyers’ countries. Registering in a low-tax jurisdiction does not remove the obligation to pay VAT where the rules of the buyer’s country require it. Options for different store models are in the article a legal entity for an online store, and accepting payments in the guide Stripe, PSPs and acquiring.

Cryptocurrency and Web3

For crypto projects, the structure depends on whether the project provides digital asset services to clients. Exchanging, holding and managing clients’ assets requires a license or registration with a regulator in many countries, and banks and EMIs check such companies especially closely. Developing a protocol, selling software or holding the company’s own assets is simpler. The models are reviewed in the article a structure for crypto and Web3.

Holding company

A holding company holds stakes in operating companies and receives dividends. Its jurisdiction is chosen based on taxes on dividends and on the sale of stakes, double tax treaties and how familiar the jurisdiction is to investors and banks. For groups with investors, the Cayman Islands and the BVI are considered; for the European operating part, a GmbH in Austria. In the BVI, holding business is also on the list in the economic substance law.

Groups with consolidated revenue of €750 million or more in two of the four preceding years are subject to the Pillar Two rules: if the group’s effective tax rate in a country is below 15%, the group pays a top-up for the difference. Small and medium-sized businesses rarely reach this threshold, though investors in large groups take it into account. More in the guide an international holding company.

Asset holding

For real estate, stakes and investment portfolios, separate companies are used to separate risks and make asset transfers easier. For such tasks, Nevis with its IBC and LLC forms, Panama and the BVI are considered. The origin of the assets will have to be proven to the agent and the bank. What such a structure protects and where its limits lie is covered in the guide asset protection.

Economic substance

The BVI economic substance law (Economic Substance (Companies and Limited Partnerships) Act, in force since 1 January 2019) lists nine relevant activities: banking and insurance business, fund management, finance and leasing, headquarters, shipping, holding business, intellectual property, distribution and service centers. In the Cayman Islands, a similar law has been in force since 1 January 2019 and was adopted following work with the OECD Forum on Harmful Tax Practices. If the activity is on the list, the BVI law requires it to be directed and managed from the jurisdiction and to have staff, expenditure and premises there proportionate to its scale; for a pure equity holding company that only holds stakes, the requirements are reduced. This changes the budget. We check the requirements before registration.

The owner’s taxes and CFC rules

Any structure must withstand a tax audit in the owner’s country. We take into account CFC rules, the company’s tax residency by place of management and the exchange of account information under the CRS (see the article on CRS in 2026 and the guide CFC rules and the offshore company).

How we select an offshore structure

  1. Questionnaire: business activity, clients, suppliers, team, the owners’ residency.
  2. Two or three structure options with taxes, banking and annual obligations.
  3. A calculation of registration and running costs for each option.
  4. Registration, bank preparation and ongoing support for the chosen option.

For the questionnaire, it helps to have a product description, a list of the countries of clients and suppliers, the expected monthly turnover, the team and where it works, and the country of tax residency of each owner. The more accurate the data, the fewer options drop out at the banking stage.

Popular jurisdictions

BVI offshore company · Hong Kong · Panama · Singapore · Belize · Nevis · Cayman Islands · United Kingdom · all offshore jurisdictions

Frequently asked questions

Which jurisdiction suits an IT company?

For selling services to Western clients, a UK Ltd is a common choice: corporate income tax of 19–25% and reporting that clients understand. For work with Asia, Singapore and Hong Kong are considered. The choice depends on the clients, the team and the owner’s residency.

Where should I register a trading company?

For trade with Asia, Hong Kong with its territorial basis of taxation is often considered, taking into account the FSIE regime in place since 2023. The decision depends on the goods routes, banks and buyers’ countries.

Does a holding company need economic substance?

In the BVI, holding business is on the list of activities in the economic substance law, so the requirements for a holding company need to be checked in advance. The scope of the requirements depends on the jurisdiction and the nature of the holding company.

What company should I set up for an online store?

The choice depends on the marketplace or acquirer, the buyers’ countries and their VAT rules. Registering in a low-tax country leaves the obligation to pay VAT in the buyers’ countries in place, so we model the whole setup.

Can I set up an offshore company for a crypto project?

Yes. Keep in mind that exchanging, holding and managing clients’ digital assets requires a license or registration with a regulator in many countries, and banks check such companies more closely. We select the structure for the project’s specific model.

How do I account for the owner’s taxes (CFC rules)?

The owner’s country of residence may tax the profits of a foreign company under CFC rules, and account information is exchanged under the CRS. We take this into account when choosing the structure and propose a setup that can be declared.

Describe your task in the form below: we will select a solution and send an estimate that separates government fees from our services.

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Tell us what kind of company you are looking for

Describe the business activity, the countries of clients and suppliers, and the owners’ residency. We will propose two or three structure options with a calculation of running costs.

Or write to us directly: info@offshora.com