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Jurisdiction Comparison

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OVERVIEW

Common features

  • based on English law system
  • no requirement for a local director
  • local registered office and registered agent required, as appropriate
  • no tax on non-local income
  • no capital gains
  • no exchange controls
  • Know Your Client (KYC) and Client Due Diligence (CDD) required
  • qualified parties may collect and keep KYC and CDD on behalf of the local registered agent
  • annual government fee payable to local government or agency

For a detailed comparison of commonly used jurisdictions click on the Download PDF button above.

Bermuda

Bermuda

Bermuda comprises a group of more than 150 small islands situated in the North Atlantic Ocean about 917 km from the coast of North Carolina, USA. Bermuda is a British Overseas Territory and has enjoyed internal autonomy since June 1968, while the UK controls the external affairs and internal security of Bermuda through the office of a Governor.

English is the common language, however Portuguese is also in use. Bermuda follows the British-based legal system. The currency is the Bermudian Dollar, which is pegged at parity to the US Dollar.

A Bermuda company is an exempted company designed by foreign investors, which does not have to pay capital gains tax, value added tax, sales tax or gift tax. Bermuda companies can be listed on all the major stock exchanges around the world.

Tourism is the second largest industry after financial services, with tourists arriving by cruise ship or air to enjoy the luxury tourist facilities.

BVI

British Virgin Islands

The British Virgin Islands (BVI) is a group of over 40 islands in the Caribbean Sea located approximately 80km east of Puerto Rico. The BVI is a British Overseas Territory which became self-governing in 1967 and is a member of the British Commonwealth. The UK is represented through the office of a Governor responsible for external affairs, defense, internal security and the public service.

Because a BVI company is not required to pay tax, nor bound to foreign exchange controls, and information for submission for filing requested by local government is minimal, many multinational companies and persons are attracted to register BVI companies. Since 1984 the BVI offshore financial services sector has flourished thanks to innovative legislation supported by a robust legal and financial services infrastructure, and today it is the world’s most popular offshore jurisdiction. BVI companies can be listed on the major stock exchanges around the world, including the Hong Kong Stock Exchange.

English is the official language of the territory and the currency is the US Dollar. BVI follows the British-based legal system.

In addition to the financial services, tourism is a major contributor to the BVI economy. There are daily flights between the BVI and USA, with cruise ships also arriving weekly to the Islands transporting tourists eager to experience its spectacular beaches.

Cayman Islands

Cayman Islands

The Cayman Islands, which comprises three islands in the Caribbean Sea south of Cuba, is situated approximately 770km/480 miles southeast of Miami. The financial services sector is one of the main industries in the Cayman Islands, and there is a substantial commitment to the continued development of the offshore financial services industry. The reputation and popularity of the Cayman Islands have increased significantly, particularly in Asia, as it is one of only two offshore centres to be approved by the Hong Kong Stock Exchange for public listing in the Hong Kong bourse prior to 2009. The Cayman Islands established its own Stock Exchange in 1997.

The official and spoken language is English and Cayman follows the British-based legal system. The official currency is the Caymanian Dollar.

Miami is one hour away by air and the Island has direct air links with other US cities and Jamaica. The Islands are also a popular cruise-ship stop.

Hong Kong

Hong Kong

Hong Kong is the leading Asian centre for both finance and commerce and ranks as the world’s third largest financial centre after New York and London. The city is a major gateway for investment and finance into the PRC and the rest of Asia.

Hong Kong is well known for its modern infrastructure and business friendly environment and has been consistently ranked number one in the Index of Economic Freedom (published by the Wall Street Journal and the Heritage Foundation) since the survey’s inception in 1995.

Hong Kong offers an open market with no import duties, a low and simple tax regime where capital gains and earnings outside of Hong Kong are tax-free. The banking sector is well regulated and the Hong Kong Dollar, pegged to the US Dollar, is freely convertible. Hong Kong’s stock market is the third largest in Asia after Japan and Shanghai. It provides foreign investors with a certain familiarity thanks to its high levels of corporate governance, risk management and high capital adequacy ratios and is the top choice for PRC companies looking to raise capital offshore.

Hong Kong’s legal system is completely independent from the legal system of mainland China. Hong Kong continues to follow the English Common Law system established under British rule. English and Cantonese are the official languages of Hong Kong, however Mandarin is increasingly widely spoken especially in business.

Marshall Islands

Marshall Islands

The Marshall Islands (officially the Republic of the Marshall Islands) are located in the Central Pacific Ocean approximately halfway between Indonesia and Hawaii, and are the easternmost island group in Micronesia.

Politically, the Marshall Islands is a presidential republic in free association with the United States, with the US providing defense, subsidies, and access to US-based agencies. With few natural resources, the islands’ wealth is based on a service economy, as well as some fishing and agriculture. The Marshall Islands only recently began to be viewed as a tourist destination with its sandy beaches surrounded by coral reefs and crystal-clear lagoons, which together with the ocean make it an idyllic destination for snorkeling, scuba diving, sport fishing and sailing. International flights to the capital, Majuro, route through other islands in the Pacific.

The country uses the US Dollar as its currency and whilst its official language is Marshallese, the use of English is very common. The Marshall Islands use Common Law for corporate matters.

Singapore

Singapore

Singapore is located at the southern tip of Peninsular Malaysia. One of the original tiger economies, Singapore is now a major international financial and trading centre that rivals Hong Kong as the world’s biggest container port. Singapore has a reputation for being highly regulated, while in reality, it is a carefully administered jurisdiction.

Singapore is a sophisticated international business and financial centre and as such, there are numerous domestic and global banks, stockbrokers and finance houses. All the major international legal and accounting firms have offices in Singapore. Singapore has a stable government and a rich pool of professionals who are able to assist in all international business transactions. English is one of the four official languages of Singapore, and it is the main language of administration and international business.

Singapore follows the English legal system.

United Kingdom

United Kingdom

A major gateway to the European Union, the world’s largest single market, the UK is the top destination for foreign direct investment into Europe.

The UK has a large, integrated transport system including the largest air transport system in Europe and Europe’s second largest ports industry contributing to fast, low-cost transportation throughout Europe and beyond.

The UK’s parliament is one of the oldest in the world and its respected legal system forms the basis of law for numerous countries around the world. The UK has long had a policy of minimising bureaucracy and deregulating industries in order to generate competition and allow companies with good business models to prosper. Within the European Union, the UK has the most business-friendly environment, with the least restrictively regulated marketplace and workforce, and one of the lowest corporate tax rates.

London is a global financial hub and the largest centre for cross-border banking in the world. The UK capital is also the most cosmopolitan and culturally diverse city in Europe, as well as its financial centre.

Companies based in the UK are well placed to do global business. The UK’s location and time zone make it easy to work across Asian, European and American markets. And it is home to the international language of business: English.