Jurisdictions

Jurisdictions

Services are available in the following jurisdictions

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Czech Republic

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Saudi Arabia

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If you need practical legal and compliance support for cross-border operations, please get in touch with a brief overview of your business model, the jurisdictions involved, and your key counterparties—such as banks, EMIs, PSPs, or other partners. Based on that information, a proposed scope of work and recommended next steps can be provided.

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    There is no best jurisdiction

    Jurisdiction lists sold as rankings are marketing. The right jurisdiction is a function of what your business does, who your counterparties are, where your money settles, who owns you and what you will need to prove in two years to a bank, an auditor and a tax authority. Change any one of those and the answer changes with it.

    Cyprus is our base and it is frequently the answer, but it is not the answer by default. A structure that is tax-efficient and unbankable is worthless; a structure that opens accounts easily but cannot carry a licence application is a dead end. What follows is the actual decision framework we apply, rather than a brochure of flags.

    The one constant across every jurisdiction we work with is that the resulting structure must be due-diligence ready — explainable on demand, from a single file, to a bank MLRO, a regulator, a statutory auditor and a tax inspector.

    The 2026 landscape in short

    15% Cyprus corporate income tax from 1 January 2026, up from 12.5 percent
    10 jurisdictions on EU Annex I of the non-cooperative list as at 17 February 2026
    25% the ownership threshold above which beneficial ownership is registrable in Cyprus
    1 Jul 2026 end of the MiCA transitional period across the EU

    Six criteria that decide the answer

    These are applied in order. A jurisdiction that fails an early one is not rescued by scoring well on a later one.

    01

    Bankability for your actual activity

    Not whether banks exist there, but whether banks and EMIs will onboard your specific activity, from that jurisdiction, with your ownership. This is the first filter because it is the one that most often eliminates the theoretically elegant answer, and it changes faster than tax law does.

    02

    Licensing feasibility and timeline

    Whether the authorisation you need exists there, what the regulator actually approves in practice as opposed to what the statute permits, the realistic timeline, and whether your payment providers and counterparties will accept a licence from that regulator at all.

    03

    Reputation and list risk

    The EU non-cooperative list, national blacklists, and correspondent-bank appetite. As at 17 February 2026 Annex I carries ten jurisdictions, including Panama, Russia and Vanuatu, and Annex II a further nine under commitment. Being on either list changes withholding tax, banking access and counterparty willingness.

    04

    Substance you can genuinely maintain

    Every credible jurisdiction now tests management and control, not registration. If you cannot maintain real decision-making, premises and people there, the structure will fail a residency challenge later. Choosing a jurisdiction you cannot staff is a deferred problem, not a solved one.

    05

    Treaty network and effective rate

    The headline rate matters much less than the effective rate after withholding taxes, participation exemptions and treaty relief across the whole chain. Cyprus at 15 percent with an extensive treaty network frequently beats a nominal zero-rate jurisdiction once dividends and interest actually have to move.

    06

    Exit, restructuring and reversibility

    How hard it is to migrate, redomicile, liquidate or sell later. Jurisdictions that are cheap to enter and expensive to leave are a common and costly mistake, and the cost usually lands at exactly the moment you have the least flexibility.

    Where we work, and what each is actually good for

    A short, honest characterisation rather than a sales pitch. Each of these is the right answer for some businesses and the wrong answer for many others.

    Cyprus

    An EU member state with an extensive treaty network, an English-derived company law under Cap. 113, and a workable substance and licensing environment. From 2026 corporate income tax is 15 percent, special defence contribution on dividends for resident and domiciled individuals fell to 5 percent, deemed dividend distribution was abolished and loss carry-forward extended from five to seven years. Strong for holding structures, EU-facing operating companies, fintech and iGaming with genuine substance. Weaker where you need a zero-rate answer or cannot maintain a real presence.

    The wider EU and EEA

    Where the deciding factor is a specific regulator or a specific licence — payments, e-money, crypto-asset services under MiCA now that the transitional period closed on 1 July 2026, or a particular gaming authority. Passporting across the single market is the reason to accept a higher compliance burden, and DORA has applied since 17 January 2025 to essentially every regulated financial entity in scope.

    The United Kingdom

    Credible for trading, professional services and holding IP where UK counterparties or UK banking matter. Outside the EU single market since Brexit, so passporting arguments no longer apply, and the effective tax position needs modelling rather than assumption. Frequently combined with an EU entity rather than used alone.

    The UAE and other non-EU hubs

    Useful where operations, people and customers are genuinely there, and increasingly difficult where they are not. Economic substance requirements and correspondent-bank scrutiny have removed most of the historic advantage of a nominal presence. Best treated as an operating jurisdiction, not a paper one.

    Common structuring questions we resolve

    These are the questions that actually determine the jurisdiction, and they are rarely the ones people arrive with.

    • Whether a single EU entity is enough, or whether an operating and a holding company should sit in different jurisdictions
    • Whether tax residency should follow incorporation or management and control, and what evidence supports the chosen position
    • Whether the intended licence is realistically obtainable from that regulator within your timeline and budget
    • Whether your payment providers, acquirers and counterparties will accept a licence from that jurisdiction
    • Whether the substance you can actually maintain matches what the jurisdiction will test — premises, people, decisions and records
    • How beneficial ownership will be registered and who will be able to see it under the legitimate-interest regime
    • Whether nominee arrangements are appropriate, and how they sit inside a fully disclosed structure — see Exclusive Nominee Services
    • What migration, redomiciliation or liquidation would cost if the structure has to change in three years

    Direct answers

    Is Cyprus still worth it after the 2026 tax reform?

    For most of the structures we build, yes. Corporate income tax rose from 12.5 to 15 percent, but the same reform cut special defence contribution on dividends for resident and domiciled individuals from 17 to 5 percent, abolished deemed dividend distribution and the Stamp Duty Law, and extended loss carry-forward from five to seven years. The effective rate on a full chain often improved rather than worsened. What it did do is make structures designed under the old rules worth re-testing.

    Should I use a zero-tax jurisdiction instead?

    Rarely, and almost never on its own. A nominal zero rate is of little use if dividends cannot leave without withholding tax, if banks will not onboard the entity, if the jurisdiction appears on the EU non-cooperative list, or if the tax authority where you actually live treats the company as resident there. Model the whole chain, not the headline rate.

    What does substance actually require?

    In practice: decisions genuinely taken in the jurisdiction by people with authority to take them, minuted and dated; premises appropriate to the activity; local bank operations; and records that show all of the above contemporaneously rather than reconstructed later. A registered address and a nominee director attending nothing is not substance, and every credible authority now tests for exactly that gap.

    Can I redomicile a company rather than start again?

    Often, yes — Cyprus permits both inward and outward redomiciliation, and several other jurisdictions do too. Whether it is the right move depends on the company's history: an entity with a clean record and useful contracts is worth moving, while one with a problematic banking or filing history is sometimes better retired than relocated.

    How does the EU list affect me if I am not on it?

    Through your counterparties. A supplier, customer or group entity in an Annex I jurisdiction can trigger defensive measures, enhanced due diligence, withholding tax and correspondent-bank questions even where your own entity is entirely clean. The list is reviewed twice a year and changed most recently on 17 February 2026, so a structure that was fine at inception can need re-testing.

    Do you have a jurisdiction you always recommend?

    No, and be careful with advisers who do. A firm that answers the jurisdiction question before hearing your facts is selling what it is set up to sell. Cyprus is our base and often the right answer, but a fair number of mandates end up combining an EU entity with a non-EU operating company, or pointing away from Cyprus entirely.

    This page describes the general regulatory and tax picture as at July 2026. It is general information, not legal or tax advice, and it does not create a lawyer-client relationship. Rules change and outcomes depend on facts — get in touch before acting.