Offshore blacklist. What are black offshores? List of the Ministry of Finance

Given the specifics of individual regions, today the authorities of each state are increasingly striving to independently maintain the so-called black list. The selection principle takes into account the peculiarities of taxation, economic ties, and a number of other criteria. Based on this, lists of jurisdictions are created, with which transactions are not prohibited, but they fall under special control.

Russian blacklists

The reason for the creation of such lists was the passage of huge capital bypassing the state treasury of a state. In this regard, entire lists of zones were compiled, cooperation with which is very strictly checked and heavily taxed. does not provide for significant restrictions that would become an obstacle to working with offshore companies, but strongly recommends that those who decide to go offshore take into account these ratings.

Of greatest interest in Russia are the data contained in the lists of such departments:

• Central Bank of the Russian Federation;
• Ministry of Finance;
• OECD;
• FATF;
• Ministry of Taxes.
• The Federal Tax Service.

Each country decides for itself what measures should be taken regarding those who risk working with such zones.

List of the Federal Tax Service

OECD

The Organization for Economic Cooperation and Development includes more than 30 countries. The list compiled by this body contains states that have not adopted requirements for the disclosure of confidential information regarding any tax matters. All offshore companies in this list can be divided into three categories:

1. Countries that have partially adopted this requirement. For example, USA, Denmark, Greece, Mexico, Italy, Poland, France, Finland and many others.
2. States that have adopted OECD requirements but have not implemented them sufficiently. For example, Monaco, Andorra, Bahrain, Bahamas and some others.
3. Zones that have not adopted the requirements: Labuan, Costa Rica, Philippines, Uruguay.

The lists of the last two organizations are constantly being corrected and changed.

What are offshore companies and how to work with them: Video

The first offshore zones appeared in the middle of the last century. In just one or two decades, offshore business has turned into a developed industry, which even some fairly large states, such as Panama, have staked on. With the growth of the processes of globalization of the world economy, the scale of the use of offshore mechanisms has only increased. This led to the fact that reverse processes began - many leading countries of the world began to pursue an anti-offshore policy. Russia was no exception, having introduced its own so-called offshore black list in 2007.

Optimal taxation options, opening companies and accounts in offshore zones, assistance in choosing ready-made offshore companies.

Reasons for the anti-offshore policy and the emergence of the term "black offshore"

An offshore is a territory or a country where the official leadership and adopted legislation create conditions for attracting foreign companies to register in these areas of jurisdiction. It should be noted that offshore business is absolutely legal and legal. This is confirmed by the fact that such services are offered by the United States, Great Britain, and Switzerland - countries that are difficult to suspect of stimulating criminal activity and breaking laws.

What caused the emergence of an anti-offshore policy, which is expressed in the compilation of various lists of black offshores and other activities, by a number of states, including Russia and those listed above? The situation is explained quite simply. Quite often, offshore schemes are used for one of the most common economic and financial crimes - tax evasion or evasion. This happens because a foreign company or individual When registering offshore, they comply with the laws of the offshore country, but at the same time violate the laws of the state of which they are a resident.

In addition, offshore companies often carry out financing of terrorism in its various manifestations. In this matter, positions developed countries and Russia are also very similar.

In fact, offshore countries, while maintaining the privacy they declare and the secrecy of the client's deposits and operations, help him commit a crime. That is why in last years there is constant pressure on almost all offshore countries (including developed ones - for example, Switzerland) in order to disclose their information about foreign clients, it does not matter whether it is an individual or a legal entity. That is why the scandals, one way or another connected with offshore companies, both Cyprus and Panama, sound so loud.

Russian anti-offshore laws and the list of offshores of the Ministry of Finance

Since the introduction market economy, the popularity of using offshore companies by Russian entrepreneurs and companies is steadily growing. This generally coincides with the global trend. Thus, according to some estimates, despite the actively pursued anti-offshore policy in the world, the total amount of funds in various offshore zones in 2016 will amount to 32 trillion rubles. dollars.

The first list of offshore companies in Russia was compiled by specialists from the Russian Ministry of Taxes and Duties in 2002. It was incomplete, since it contained a list of only 25 (out of more than fifty operating at that time) offshore zones. Subsequently, employees of the Central Bank of Russia also took part in compiling and editing the list of offshore companies.

Blacklist of offshores of the Ministry of Finance

In 2007, the Ministry of Finance joined this work, which released its own list at the end of the year, which received the almost official name of the Ministry of Finance's offshore black list. It came into force on 01.01.2008 and is edited almost every year, taking into account changes in the legislation of the states and territories mentioned in it. Initially, the list of offshores of the Ministry of Finance included 42 countries or zones.

Cooperation with companies registered there could result in additional tax. But this applied only to dividend payments, in addition, the legislation in force at that time provided serious benefits to large businesses. Because of these two reasons, the appearance of the list of black offshore companies did not have any special consequences for Russian business.

Deoffshorization and the CFC Law

Not surprisingly, Russian legislators have continued to make changes and issue new laws related to limiting the participation of domestic companies and individuals in offshore business.

A special term “deoffshorization” has appeared, the meaning of which is extremely clear. Within the framework of the deoffshorization company, in 2013, amendments were made to the Federal Law “On Combating Money Laundering”, and from 01.01. offshore).

This law, in fact, is a modern and greatly expanded version of the offshore blacklist of the Ministry of Finance. In addition to the actual offshore states and territories, it also contains a list of countries that "do not provide information exchange for tax purposes." Therefore, on this moment black offshore companies include:

• 22 territories, among which the most famous are:
  • British Virgin Islands and US Virgin Islands;
  • Curacao;
  • Isle Of Man;
  • Republic of Niue;
  • Puerto Rico;
  • Cayman Islands and others;
• 109 states, including such famous ones as:
  • Angola;
  • Bangladesh;
  • Belize;
  • Brazil;
  • Dominica;
  • Nigeria;
  • Jamaica and many others.

It should be noted that the United Kingdom and Switzerland were also present in the original draft law, but they were excluded in the final version. At the same time, traditional Cyprus and Luxembourg, which have been successfully developing offshore business for a long time, are not on the black list of offshore companies.

The law came into force not so long ago, so it is rather difficult to say what consequences it will lead to. But before April 1, 2015, all domestic residents had to submit information to the tax office about their participation in the activities of foreign companies.

Conclusion

Given the trends that are actively manifesting in the global economy, the anti-offshore policy and the compilation of various black lists of offshore companies by the most developed countries of the world will continue. There are no preconditions for Russian state was not an active participant in this policy, often leading in some aspects of the fight against offshore companies.

The presence of an offshore in the black list is an important criterion for the owner of a company registered in this offshore: he will have to apply the rules that are provided for by the Tax Code for controlled foreign companies (CFCs). According to the law, the owners of foreign CFCs must include the results of the activities of these companies (including those abroad) in the financial statements filed in Russia, which means that they must pay taxes on these incomes. Russian budget. “For Russian owners of companies registered in countries or territories included in the so-called black list of the Federal Tax Service, there is a possibility of falling under the requirements for CFCs,” Dmitry Volvach, head of the Standards and International Cooperation Department of the Federal Tax Service of Russia, told RBC.

Thus, the exclusion of an offshore from the black list is favorable for companies registered in it. Their activities will not be considered as controlled, which means that the results of these activities in general case are not taxed in Russia.

But at the same time, the owners of such companies have less opportunities for tax optimization. For example, in a situation where an offshore company does business in Russia without tax registration or beneficiaries use this company as a transit company with subsequent transfer Money offshore black. Having found out the real owners of companies from white offshores, the tax authorities quite easily identify their affiliation with a Russian counterparty, which entails additional taxes.

Background

The reason for the exclusion of BVI from the black list was the complete "whitewashing" of this offshore in current year. To improve business transparency, the BVI authorities have taken whole line measures. The key one is that in July 2017, the BVI launched a centralized register of business owners, the Beneficial Ownership Secure Search System (BOSS). The register contains the data of all business structures registered on the islands, including the name, date of birth and citizenship of the owner.

The system itself is not public, but the BVI authorities have automatic access to it. From it, they will also provide information at the request of Russian tax authorities.

BVI became the first offshore jurisdiction to create state base information about beneficiaries. Creation similar bases data on beneficiaries is provided for by the 4th EU directive against money laundering (4th Anti-Money Laundering Directive, AMLD4), adopted back in 2015. The databases must contain information about the real owner - the beneficiary of the company, even if he controls it through a chain of offshore firms. This is the difference between the databases of beneficiaries from such registries as, for example, SPARK or the Unified State Register of Legal Entities, where nominal owners are disclosed.

According to Russian legislation the beneficial owner is an individual who owns or controls more than 25% of the capital of the company (such a definition is given in the law on combating the legalization (laundering) of proceeds from crime and the financing of terrorism).

Information exchange

After the entry into force of the order of the Federal Tax Service to exclude BVI from the offshore blacklist, the exchange of information about the real owners of companies registered on the islands between the tax authorities of Russia and the BVI will take place on the basis of the Convention on Mutual Administrative Assistance in Tax Matters.

The BVI authorities signed this convention in 2016. In 2017, the exchange took place in a test mode, and from 2018, after BVI is excluded from the offshore blacklist, it will become regular, and most importantly, quite prompt, the Federal Tax Service explained to RBC. “Next year, we are already counting on a regular exchange of information with the tax authorities of the BVI. We expect that we will receive meaningful answers to our requests from the BVI authorities and within a reasonable time (three to four months),” Dmitry Volvach explained to RBC.

This is much faster than the previous channels. If you act through Interpol, as is the case with blacklisted offshore companies, obtaining the necessary information will take much longer, experts interviewed by RBC indicate. "At tax authorities it is possible to request information from any offshore through Interpol. But, firstly, Interpol may refuse the request, and even if it does not refuse, then you will have to wait about a year for an answer. Secondly, the tax service does not apply to Interpol directly, but through the Ministry of Internal Affairs, which does not simplify the procedure,” explains the senior adviser. law firm Hill Consulting Sergey Nesterenko.

The Federal Tax Service of Russia also plans to respond to requests from colleagues from the BVI, if any follow.

Possible consequences

The opinions of lawyers about whether the popularity of BVI in Russia will decrease due to innovations, and if so, how much, are divided.

“BVI has always been a very popular offshore. Businesses were attracted by the simplicity of registration procedures and understandable legislation based on English law,” Sergey Panushko, Head of the International Corporate Law Department at GSL Law & Consulting, shares his experience.

“BVI is one of the leaders in direct investment in the Russian Federation among offshore jurisdictions: in particular, the volume of investments last year amounted to $1 billion," Aleksey Gaidov, managing partner of Gestion, told RBC. About 700 thousand companies are registered on the BVI, that is, about 40% of all world offshore companies, he added.

“Of course, the risk of disclosure of the ownership structure for beneficiaries registered on the BVI will now increase significantly,” Sergey Nesterenko predicts. Consequently, the risk of tax claims against them also increases if BVI companies were used for illegal tax optimization, experts say.

The courts, when considering such cases, apply the model convention on taxes on income and capital of the Organization for Economic Cooperation and Development - it introduces the concept of beneficial ownership. This concept is based on the principle that transactions are subject to tax accounting based on their real economic content and not legal form.

Typical in this regard is the “case of PJSC Vladimir Energy Retail Company (PJSC VEK)”. According to the tax office, Joint-Stock Company implemented a scheme to reduce income tax with the involvement of companies registered in the Republic of Cyprus and the British Virgin Islands in the settlement chain.

The essence of the scheme, according to the judges, was as follows: PJSC VEK, being the ultimate beneficiary of an offshore company on the BVI, issued a purchase of 100% of the shares of Energoservice affiliated with it for this company. But as a technical buyer (created only for the transfer of funds under the transaction) used a company registered in Cyprus. This made it possible for PJSC "VEK" to apply the income tax relief, since Russia signed an agreement on the avoidance of double taxation with Cyprus. As a result, the tax amounted to 5% of the amount received under the transaction, while if the shares were sold directly, the "daughter" with BVI would have to withhold and pay tax in the amount of 20% of the transaction amount. It became possible to identify a real buyer (a BVI company) as a result of information received from Cypriot colleagues.

PJSC "VEK" sued, but the courts of first and second instance supported the tax inspectorate. Court of Cassation - Arbitration court Volga-Vyatka District - by a resolution of August 7, 2017, left the decisions of the lower courts unchanged (copies judgments posted in the ATP "Consultant Plus").

Had the exchange of information with the BVI been in place at that time, the scheme would have been exposed more quickly.

Risk aversion

According to lawyers, a number of companies that do not want disclosure may change jurisdiction.

So, companies that seek to minimize the risk of disclosure of the owner's structure, today choose, for example, the Bahamas or US special territories, Puerto Rico and the US Virgin Islands, says Sergey Nesterenko. First, he explains, these territories have not signed the Convention on Mutual Administrative Assistance in Tax Matters, and therefore, direct exchange of information with them is impossible. Secondly, they do not belong to the overseas territories of Great Britain and are not part of the British Commonwealth of Nations - an association of independent states that includes Great Britain and many of its former dominions, colonies and protectorates, whose members almost always provide information at the request of English courts.

Many wealthy Russians own assets in countries and territories that are part of the British Commonwealth. Ownership of assets, as a rule, is formalized through trusts and funds, and management is carried out through principals (trustees), Sergey Nesterenko explains. The beneficiaries of trusts and funds registered in countries or in the Commonwealth territories can be disclosed at the request of the English court, he adds.

Actually, these risks materialized in relation to the New Zealand trusts (New Zealand is part of the British Commonwealth) of Sergei Pugachev, the beneficiary of Mezhprombank (the largest Russian bankrupt bank). By order of the English court, the trustee of the trust disclosed information about its assets. Thus a link was established between the banker and the assets held in trust. This, as well as, made it possible for the Deposit Insurance Agency to apply to the High Court of London with a demand to recognize Pugachev as the beneficiary of New Zealand trusts.

There are no guarantees

However, according to the lawyer of BGP Litigation Anastasia Berman, the transition to a black offshore does not guarantee anything in itself. The essence of the concept of beneficial owner actively applied by the courts implies that any tax benefits provided for by international agreements can only apply to beneficial owners, real owners companies. And the practice in cases of challenging the status of a beneficial owner is mostly negative for the taxpayer, the lawyer adds.

However, sometimes companies from such jurisdictions manage to beat the tax authorities in court. For example, in August 2017 the Arbitration Court of the Kaliningrad Region upheld a taxpayer in a dispute with tax service(the court decision is at the disposal of RBC).

The organization borrowed from companies registered in Hong Kong and Cyprus. Tax office found out that control over all companies involved in the transaction is exercised through a company registered in Jersey - a state that is included in the black list of the Federal Tax Service. The tax authorities considered that in this case, the cost of interest on the loan cannot be taken into account for income tax purposes in accordance with the legislation on CFC.

In this case, the company was able to prove that the funds of the group of companies were used for current activities, and were not transferred in the form of dividends or loans to the ultimate beneficiary in Jersey, says Anastasia Berman.

However, if the change of jurisdiction helps, then only for a while, says Stanislav Lyaptsev, Leading Legal Adviser of the Department of Legal Consulting and Tax Practice of KSK Group. “The practice will still develop towards disclosing foreign transit companies and finding the actual beneficial owner, and the relevant EU directive also contributes to this,” he says.

A number of experts still believe that there will be no outflow of business from the BVI in order to avoid possible claims from the tax authorities. The authorities of the islands have always taken into account the recommendations of the FATF and the OECD, and banks are willing to work with jurisdictions that follow international trends in a reasonable way. “We do not expect a decrease in interest in the BVI in Russia,” says Sergey Panushko. In addition, he adds, several hundred thousand companies are registered on the BVI and the authorities of this jurisdiction simply will not be able to promptly provide information on all companies.

The black list of offshore zones of the Ministry of Finance (offshores, offshore zones) - this is the name of the List of states and territories that provide preferential tax regime taxation and (or) not providing for the disclosure and provision of information during the financial transactions(offshore zones), approved by Order of the Ministry of Finance of the Russian Federation of November 13, 2007 N 108n (see).

The word offshore comes from the English offshore - “out of the coast”, since the main offshores are located on small island states.

The so-called black list of offshore zones was approved by the Order of the Ministry of Finance of the Russian Federation of November 13, 2007 N 108n and entered into force on January 1, 2008. Interaction with companies registered in the states indicated in the list, in some cases entails adverse tax implications for Russian taxpayers:

So, Russian company receiving dividends, in some cases it has the opportunity to apply a 0% rate (clause 3 of article 284 tax code). But this rule does not apply if dividends are received from an organization registered in a state from the black list of the Ministry of Finance.

The relief provided for in s. 11 p. 1 art. 251 Tax Code of the Russian Federation when receiving property Russian organization does not apply free of charge if the organization transferring property is a foreign organization and the state of permanent location of the transferring organization is included in the black list of the Ministry of Finance of the Russian Federation.

Transactions with companies registered in the state from the black list of the Ministry of Finance are recognized as controlled (see), which entails the right to control the prices of transactions by the tax authorities and the obligation of the taxpayer to declare such transactions (in case the amount of transactions established by the Tax Code for the year is exceeded) - paragraph . 3 paragraph 1 and paragraph 7 of Art. 105.14 of the Tax Code of Russia.

It should be noted that the Ministry of Finance regularly makes changes to this list, excluding “corrected” states or adding new offshore zones.

Since January 1, 2018, the Hong Kong Special Administrative Region (Hong Kong) has been excluded from this list (No. 16, Order of the Ministry of Finance of Russia dated November 2, 2017 N 175n)

Since January 1, 2015, the Republic of Malta has been excluded from this list (No. 23, Order of the Ministry of Finance of Russia dated 02.10.2014 N 111n);

Since January 1, 2013, the Republic of Cyprus has been excluded from this list (No. 15, Order of the Ministry of Finance of Russia dated August 21, 2012 N 115n);

Since March 17, 2009, the Republic of Seychelles has been added to the list (No. 42, Order of the Ministry of Finance of the Russian Federation of 02.02.2009 No. 10n).

Meaning of the Offshore Blacklist

In the Tax Code of the Russian Federation, the Black List of offshores is mentioned in the following norms:

Controlled transactions

In transactions with companies from the states specified in the Offshore Black List, a lower threshold for recognizing transactions as controlled is set at 60 million rubles (clause 3, clause 1, article 105.14, clause 7, article 105.14 of the Tax Code of the Russian Federation). Moreover, to recognize such transactions as controlled, the interdependence of persons is not required (it is enough to achieve the amount threshold established by paragraph 7 of article 105.14 of the Tax Code of the Russian Federation of 60 million rubles per calendar year) (cm. ).

Dividends

The 0% dividend rate does not apply if the party paying dividends is located in a state included in the black list of the Ministry of Finance (clause 1, clause 3, article 284 of the Tax Code of the Russian Federation).

Benefits for gratuitous receipt of property

The relief provided for in s. 11 p. 1 art. 251 of the Tax Code of the Russian Federation, when receiving property by a Russian organization free of charge, does not apply if the organization transferring the property is a foreign organization and the state of the transferring organization's permanent location is included in the black list of the Ministry of Finance of the Russian Federation.

Controlled foreign companies

If Russian face owns directly or indirectly a company from the Black List of the Ministry of Finance, then such a person, in most cases, is recognized controlled person, and the company from foreign country- . So profit controlled foreign company exempt from taxation if its permanent location is a state (territory) with which there is an international agreement Russian Federation on taxation issues, with the exception of states (territories) that do not provide for the exchange of information for taxation purposes with the Russian Federation, and effective rate taxation of income (profit) for this foreign organization, determined based on the results of the period for which, in accordance with the personal law of such an organization, financial statements for the financial year, is not less than 75 percent of the weighted average tax rate for corporate income tax (clause 3, clause 7, article 25.13 of the Tax Code of the Russian Federation). For companies from the countries of the Black List of offshores of the Ministry of Finance, these requirements, as a rule, are not met.

Other Offshore Blacklists

In addition to the Black List of offshores of the Ministry of Finance of the Russian Federation, approved by the Order of the Ministry of Finance of the Russian Federation of November 13, 2007 N 108n, there are other, similar lists compiled for other purposes.

So, the Federal Tax Service of Russia draws up a List of states (territories) that do not provide information exchange for tax purposes with the Russian Federation (). The compilation of such a list is provided for in paragraphs. 3 p. 7 art. 25.13 of the Tax Code of the Russian Federation and, first of all, is used for the purposes of determining controlling persons and.

Bank of Russia Ordinance No. 1317-U, dated 07.08.2003, "On the Procedure for the Establishment of Correspondent Relations by Authorized Banks with Non-Resident Banks Registered in States and Territories Providing a Preferential Tax Regime and (or) Not Providing for the Disclosure and Provision of Information when Conducting Financial Transactions ( offshore zones)" defines the list of offshore companies and divides them into three categories. The amount of the reserve is set depending on the offshore category. The maximum reserve is set for offshores of the third category.

Big business, as you know, requires paying big taxes. And everyone here is trying to somehow circumvent the requirements provided for by law. Someone breaks the law, and someone is looking for completely legal ways. Offshore is one option for legally avoiding paying taxes or reducing their amount to a minimum.

The concept of offshore

There are certain territories, and even entire countries, which, for their development, are not averse to attracting the capital of large foreign business companies almost free of charge. In return, they offer either full tax exemption or very attractive benefits.

A company registered in such a territory usually does not conduct its business here, but carries it out abroad.

An offshore zone is a kind of tax-free and financial control the territory in which it is registered receives a legal status and formally operates a foreign enterprise. At the same time, it is not exempt from paying taxes in the country where it actually does business.

Offshore jurisdiction

An offshore jurisdiction is a country that provides companies registered on its territory with a legal opportunity not to pay taxes or pay them for certain benefits, as well as not to report on their activities and financial condition.

For the most part, such jurisdictions are small island states located around the world, the main source of filling the budget of which are state fees from registration offshore companies and its annual renewal.

What is an offshore company and what is its essence

Such companies are usually used to organize trading business. We will consider its essence in simple example standard buying and selling process. If you organize imports according to the usual scheme, the entry price for imported goods will directly depend on the actual purchase price. Naturally, various customs duties, income tax, etc. will be added to it.

An offshore zone allows you to avoid unnecessary costs if you pass the goods through a company registered on its territory, indicating in the documents any convenient cost (in our case, it is better to underestimate). This will significantly reduce the amount of customs duty and income tax.

Companies are used as holding structures, as well as enterprises to receive investment funds and accumulation of various financial resources. However, the most popular option remains the usual trading activity associated with import-export operations.

Offshore benefits

The main advantages of offshore companies include:

• absence mandatory payment taxes;
• availability of certain benefits during registration;
• the highest level of confidentiality about the type of activity, company structure, owners and shareholders;
• no need to submit information to public authorities about their activities and profits.

In the nineties, the benefits of free economic zones were widely used in all business sectors. Today, due to the tightening of control over the activities of companies, there is no such excitement, but the offshore business continues to flourish. Still, because it is the most profitable and fast way withdrawal of funds abroad.

Any such company has several bank accounts linked to the cards of the founders, shareholders and members of their families. If necessary, all the money can be quietly withdrawn abroad within a few hours.

But this is not what actually gives life to offshore companies. It's all about the absence unified system taxation in different states. So it turns out that one country is losing millions of dollars due to high tax rates, and the other due to this lives and thrives.

How legal is it

Our legislation does not prohibit establishing companies abroad or becoming shareholders of them. It is also permitted to participate fully in civil legal relations with foreign companies, provided that the legislation of the Russian Federation is not violated.

In other words, if everything happens within the framework Russian laws It means everything is legal. In fact, an offshore zone or a company is just a tool for obtaining benefits that can be used both within the law and outside of them.

Today, the international community is trying to take a closer look at such corners of the "tax haven", taking appropriate measures against some jurisdictions that refuse to cooperate transparently.

Registration features

The procedure for registering a company in most free jurisdictions is quite simple, and does not even require the presence of its founders. It is enough to send your representatives (signatories). They will need to contact the relevant public service with an application for registration, as well as to appoint a general director.

In addition, there are special bureaus that independently establish companies, having nothing to do with its true owners.

A ready-made offshore business that exists only on paper can be bought at a price of 10 thousand US dollars.

Offshore zones of the world and their types

But let's figure out which states are considered offshore zones. Today there are about 50 jurisdictions in the world. All of them are divided into:

• classic offshore (with zero taxation);
• zones with low taxation;
• offshore with a territorial method of taxation;
• offshore, where certain types of activities are exempt from taxes;
• zones where the activities of individual legal entities.

Classic variant

A classic offshore zone is a territory where a company pays an annual fee, and no taxes are levied on its activities. In addition, it is not subject to audit. The list of offshore zones of the classical type includes:

Free zones with territorial taxation

Offshore economic zones with territorial taxation provide companies with the opportunity to pay tax only on profits received from sources located in the territory of their jurisdiction. This makes it possible to attract additional investments and greatly simplifies the export process. These areas include:

• Algeria;
• Brazil;
• Bolivia;
• Hong Kong;
• Guatemala;
• Kuwait;
• Costa Rica;
• Malaysia;
• Monaco;
• Morocco;
• Nicaragua;
• Singapore;
• Paraguay;
• Uruguay etc.

Offshore zones with low taxation

Taxation in offshore zones of this type has been reduced to a minimum in order to stimulate the development of its own economy and attract foreign investment. These jurisdictions include:

Jurisdictions with taxation of certain types of activities

In these zones, not all are exempt from paying taxes, but only some companies engaged in a certain type of business. These include:

• Anguilla;
• Bulgaria;
• Hungary;
• Denmark;
• Lithuania;
• Latvia;
• Norway;
• Slovakia;
• Poland;
• Switzerland etc.

Offshore zones where some legal entities are exempt from taxation

These jurisdictions selectively, at their discretion, may exempt from taxes only individual legal entities. Such jurisdiction, for example, is the most famous offshore zone - Cyprus. It is here that many companies from Russia are registered and operate.

In accordance with the Order of the Ministry of Finance of the Russian Federation dated November 13, 2007 No. 108 H, the list of offshore zones for Russian companies, providing a preferential tax regime, includes the following territories and states:

• Andorra;
• Antigua;
• Antilles;
• Barbuda;
• Bahamas;
• Bahrain;
• Beziz;
• Brunei;
• Vanuatu;
• Virgin Islands;
• Gibraltar;
• Dominica;
• Cyprus;
• Liberia;
• Liechtenstein;
• Malta;
• Marshall Islands;
• Monaco;
• Nauru;
• Nevis;
• Niue;
• Channel Islands;
• Cook Islands;
• Palau;
• Panama;
• Samoa;
• San Marino;
• Saint Vincent;
• Grenadines;
• Saint Kitts;
• Saint Lucia;