What Is a Tax Haven? How They Work and Who Uses Them
By John Rush
Checked November 4, 2026 · How we score
"Tax haven" sounds like a place where the rich hide money. Sometimes it is. More often it's a perfectly legal jurisdiction that charges little or no tax and competes for businesses the same way Ireland, Singapore or Delaware do. The line between the two is what this guide is about.
What is a tax haven, exactly?
A tax haven is a jurisdiction that offers foreign individuals and companies little or no tax on income earned elsewhere, usually combined with some of:
- No or nominal tax on corporate profits, personal income, capital gains or inheritance
- Financial secrecy — historically, no sharing of account or ownership information with other countries
- Lack of substance requirements — companies could exist on paper with no staff or office
- Ring-fencing — low-tax treatment offered to foreigners but not to locals
Those four criteria come from the OECD's 1998 report on harmful tax competition, and they still shape how governments define the term. There's no single legal definition, which is why one country's "international financial centre" is another's "tax haven."
How does a tax haven work?
The basic mechanic is moving where profit is booked away from where it's taxed heavily.
- A company sets up a subsidiary in a low-tax jurisdiction (say, Bermuda or the Cayman Islands).
- Valuable assets — usually intellectual property, brands or financing — are owned by that subsidiary.
- Operating companies in high-tax countries pay royalties, interest or service fees to it, reducing their taxable profit at home.
- Profit accumulates in the haven at 0% or close to it.
For individuals the mechanic is simpler: become tax resident somewhere with no personal income tax (Monaco, the UAE, the Bahamas) and stop being resident where you were taxed before.
Is using a tax haven legal?
Using a low-tax jurisdiction is legal. Lying about it is not.
| Tax avoidance / planning | Tax evasion | |
|---|---|---|
| Definition | Arranging affairs to pay less tax within the law | Concealing income or assets to not pay tax that is legally due |
| Example | Moving to Dubai and becoming UAE tax resident | Keeping undeclared money in a Swiss account while living in France |
| Legal? | Yes (though aggressive schemes can be challenged) | No — criminal offence |
| Disclosure | Fully reported | Hidden |
Most enforcement now targets the gap in between: structures that are technically legal but lack substance. A Cayman company with no employees that "earns" €50 million of royalties is legal on paper and increasingly attacked in practice.
What are the OECD and EU tax haven blacklists?
EU list of non-cooperative jurisdictions. Updated twice a year by the Council of the EU. After the October 2026 update, Annex I (the blacklist) has 8 jurisdictions:
| EU blacklist (Annex I), Oct 2026 |
|---|
| American Samoa |
| Anguilla |
| Guam |
| Palau |
| Russian Federation |
| Turks and Caicos Islands |
| US Virgin Islands |
| Vanuatu |
Panama and Vietnam were moved to the grey list (Annex II) in October 2026. Listing triggers defensive measures in EU member states — for example, denying tax deductions for payments to listed jurisdictions or applying higher withholding taxes.
OECD Global Forum ratings. Rather than a blacklist, the OECD rates countries on exchange-of-information standards ("compliant," "largely compliant," "partially compliant," "non-compliant"). Almost every former haven now participates in automatic exchange under the Common Reporting Standard (CRS), which shares bank account data with your country of residence each year.
Note the irony: the Cayman Islands, Bermuda and the BVI — the classic havens — are not on the EU blacklist because they now share information and enforce economic substance rules.
What is Pillar Two and the 15% global minimum tax?
Pillar Two is the OECD/G20 agreement that large multinational groups (consolidated revenue of €750 million or more) should pay at least 15% effective tax in every country they operate. If a subsidiary pays less, another country can collect a "top-up tax."
Key points in 2026:
- It's in force in the EU, UK, Japan, South Korea, Canada, Australia and many others.
- Low-tax jurisdictions responded by introducing their own domestic minimum top-up taxes — Bermuda (15% corporate income tax from 2025), the UAE, Bahrain, Kuwait and others — so they collect the tax rather than letting other countries do it.
- In January 2026 the OECD published a "side-by-side" package that lets US-parented groups largely opt out of the income inclusion and undertaxed profits rules, though domestic minimum taxes still apply.
For founders and small businesses, Pillar Two changes almost nothing. If your group earns less than €750 million, zero-tax and low-tax jurisdictions still work the way they did. Pillar Two killed the haven for Big Tech, not for a five-person SaaS company.
What are CFC rules and how do they affect me?
Controlled foreign company (CFC) rules are the bigger practical constraint for founders. They let your home country tax the profits of a foreign company you control, as if you'd earned them yourself, when that company is in a low-tax jurisdiction and earns mostly passive or easily shifted income.
Examples:
- US: Subpart F and GILTI (renamed net CFC tested income from 2026) tax US shareholders on a foreign corporation's income each year.
- EU: every member state must have CFC rules under the Anti-Tax Avoidance Directive (ATAD).
- UK, Australia, Japan, Canada: all have their own versions.
So: a German resident who sets up a BVI company to invoice clients typically still pays German tax on that profit. A tax haven company only helps if you personally live somewhere without CFC rules or with a territorial system — which is why personal residence matters more than company location. See how to start a business abroad.
Which countries are considered tax havens?
Common examples, with what makes them attractive:
| Jurisdiction | Corporate tax | Personal income tax | Main use |
|---|---|---|---|
| Cayman Islands | 0% | 0% | Investment funds |
| British Virgin Islands | 0% | 0% | Holding companies |
| Bermuda | 0% (15% for large MNEs since 2025) | 0% | Insurance, reinsurance |
| Bahamas | 0% | 0% | Wealth, residency |
| Monaco | 25% if >25% turnover abroad | 0% (not French nationals) | Residency |
| UAE | 9% above AED 375,000; free-zone 0% | 0% | Founders, holding, residency |
| Panama | 25% on local income, territorial | Territorial | Holding, residency |
| Switzerland | ~12–21% combined | Varies by canton | Holding, wealth |
| Ireland | 12.5% (15% for large groups) | Up to 40% + USC | EU HQs |
| Singapore | 17%, partial exemptions | Up to 24% | Asia HQs |
| Hong Kong | 8.25%/16.5%, territorial | Up to 17% | Asia trading |
| US (Delaware, Wyoming, Nevada) | 21% federal | Federal + state | Secrecy, non-resident LLCs |
Full list with filters on our tax havens page, and the zero-tax subset on countries with no corporate tax.
Why do people still use tax havens in 2026?
Not mostly for secrecy — that's largely gone thanks to CRS. The legitimate reasons today:
- Neutral holding location for investors from multiple countries (no extra layer of tax).
- Personal relocation to a zero-income-tax country such as the UAE or Monaco.
- Simplicity — zero-tax jurisdictions often have simple accounting and quick setup.
- Fund structures — Cayman remains the default for hedge funds and many VC funds.
If you're a founder thinking about it, the right question isn't "which haven?" but "where will I live, and where is the real work done?" Our countries with no income tax guide covers the personal side.
Not tax or legal advice; rules change — verify with a local adviser.
Frequently asked questions
What is the biggest tax haven in the world?
By the Tax Justice Network's Corporate Tax Haven Index, the British Virgin Islands, Cayman Islands and Bermuda consistently rank at the top. By financial secrecy and scale, the United States, Switzerland and Singapore also rank highly.
Is the United States a tax haven?
For foreigners, partly. States like Delaware, Wyoming and Nevada allow anonymous LLCs, the US doesn't participate in the Common Reporting Standard, and non-resident-owned LLCs without US business activity pay no US federal income tax.
Is Dubai a tax haven?
The UAE has no personal income tax and a 9% corporate tax above AED 375,000, with 0% for qualifying free-zone income. It is not on the EU blacklist and requires real economic substance, so it is better described as a low-tax jurisdiction than a classic secrecy haven.
Can I legally move my business to a tax haven?
Yes, if you report everything and the company has real substance. But if you still live in a high-tax country, CFC rules and management-and-control rules usually let that country tax the profits anyway. Moving yourself matters more than moving the company.
Does Pillar Two end tax havens?
Only for large groups with €750 million or more in annual revenue, which must pay at least 15% everywhere. Small and medium businesses are unaffected and can still benefit from zero- and low-tax jurisdictions.
Related
Not tax or legal advice. Rates and rules change; we check official sources and update every page, but verify with a licensed adviser in the country before acting. Spotted something out of date? Use the correction form below.