Offshore companies haven’t disappeared – they’re just changing shape.
Stricter transparency rules, international reporting standards (CRS), and tighter CFC regulations have rewritten the rules. The old “tax haven” setups are now pricier and more complicated.
Today, offshore structures are less about dodging taxes and more about reducing risks, protecting assets, simplifying bureaucracy, inheritance planning, and managing geopolitical uncertainty.
Constantly Changing “Blacklists”
Countries regularly update their “blacklists” – such as: FATF list (countries with weak anti–money laundering systems), EU tax haven list (places that don’t share corporate or tax data), OFAC (U.S.) and EU sanctions lists (countries under financial sanctions) etc.
Banks often refuse to open accounts for companies from these places or apply strict checks, making business complicated.At the moment, only North Korea, Iran, and Myanmar are on the FATF “blacklist.” The “grey list” – which includes higher-risk countries – features not just classic offshore zones but also Bulgaria and Monaco.
To avoid being listed, many countries are tightening their laws: they demand real company presence (office, staff, activity), verify shareholders, and enforce stronger anti-money laundering controls.
Full tax exemptions are also disappearing. For example, in the United Arab Emirates, a 9% corporate tax now applies to almost all companies – no matter where profits come from.
Fewer Company Formation Agents
Starting a company offshore isn’t as easy or cheap as it used to be. Service providers must now meet strict AML (anti–money laundering) requirements – they need trained specialists, proper KYC (know-your-customer) procedures, and more. This means higher costs and fewer providers. Some registrars even refuse clients they see as risky. Their work is monitored by local authorities, so maintaining this type of business has become expensive and demanding. Therefore in many former “tax haven” countries, forming a company can now cost more and take longer than in regular onshore jurisdictions.
Modern Offshore Trends
1. Transparency Is the New Normal
Gone are the days of hiding behind complex ownership chains. Global transparency standards (like CRS) mean governments automatically share data about bank accounts. Many countries now keep registers of company owners, so confidentiality is far lower than before. Banks also avoid complicated structures, which they see as higher-risk.
Because of this, entrepreneurs now prefer simple and transparent setups – even if they’re more expensive to maintain. The goal today is not to hide but to manage properly.
2. Goodbye “Shelf Companies”
Buying a ready-made company off a list used to be popular. Now it’s nearly gone.
AML rules see “shelf companies” as risky, and new registrations require detailed information about the real owner and planned activity. For example in Switzerland, selling shelf companies is even illegal. Of course, buying an existing business is fine – but most new companies today are set up from scratch.
3. Asset Protection, Not Tax Tricks
Offshore structures are now more about protecting wealth than saving taxes. They’re often used for inheritance planning, trusts, and foundations – tools common in Anglo-Saxon law. Another growing reason? Geopolitical instability. Many business owners want their assets safe if war or economic chaos hits their assets.
4. Quality Over Quantity
Instead of having several companies in different countries, business owners now prefer one well-structured company with real substance – a genuine office, employees, and operations. The company’s setup should reflect real business reasons, such as choosing Malta for online gaming because of flexible laws. This makes it easier to explain where the money comes from and reduces tax risks.
5. Business Nomads
“Digital nomads” – entrepreneurs who can work from anywhere – often pick countries that suit their specific business (e.g., e-commerce, online services, or gaming). Since these businesses don’t need large teams, they prefer countries with simple rules and low taxes.
6. Changing Tax Residency
People who don’t have strong ties to one country often change their tax residency to save money. For example: a UAE resident pays no personal income tax. After the UK ended its “non-dom” system, many wealthy people moved to places like Malta or UAE. Some countries (like Italy or Uzbekistan from 2026) offer fixed annual tax deals for foreigners who meet certain income criteria.
Smart combinations also exist – such as a Portuguese resident owning a Maltese company – to reduce taxes on dividends for years.
7. Moving Companies Between Countries
Sometimes, companies have valuable assets or bank accounts that are hard to move. Instead of starting over, they can redomicile – transfer the company from one country to another. For example, a Seychelles company can move to Malta, keeping its old bank accounts and assets but becoming a full Maltese tax resident company.
8. Permanent Establishment
It’s possible to have a company registered in one country but pay taxes in another.
In some cases, running a permanent establishment abroad is simpler and cheaper than opening a whole new company.
9. Offshore + Onshore Mix
Sometimes, companies in low-tax countries are kept for convenience or continuity.
They may be owned by onshore companies that officially receive and record dividends. Ownership can also go through trusts or foundations, which help reduce CFC-related tax risks.
Offshore structures are making a comeback – but in a new, more responsible form.
They’re more transparent, more expensive, and require solid legal oversight. The offshore world today isn’t about hiding – it’s about building smarter, safer, and cleaner international business structures.
Jaroslavas Lukosevicius
Attorney-at-law
Creada
