How to open an offshore company and bank account in 2026
The BVI government fee is USD 550, yet finding a bank for the company takes longer than registering it. The BVI is on the FATF grey list for a second year, beneficial owners are filed with the state, and banks report accounts under CRS to the owner's tax authority. Six jurisdictions, real government fees, economic substance and what to declare at home.
The British Virgin Islands, the best-known name in the offshore world, have been on the FATF grey list (Financial Action Task Force, the global anti-money laundering watchdog) since 13 June 2025, and the plenary of 17-19 June 2026 left them there. For anyone who owns a BVI company the takeaway is simple: banks factor the grey list into their risk assessment, and the checks usually go deeper. The BVI government fee is still a modest USD 550. The hard part is getting a bank to take the company on and keeping the tax authority back home satisfied.
In 2026 an offshore company is no longer an anonymous suitcase on an island. It is a company with registers, filings and bank due diligence. Since 2 January 2025 every new BVI company must tell the state registry, within 30 days, who owns 10% or more of it. Under CRS (the OECD Common Reporting Standard for the automatic exchange of financial account information) tax authorities swapped data on 171 million accounts worth almost $15 trillion in 2024. And a Russian tax resident with an offshore company owes filings to the Federal Tax Service, with a fine of about USD 5,900 for each controlled company notice that is not filed.
None of this makes offshore companies illegal or useless. Below are six popular jurisdictions with real government fees, the path from incorporation to a bank account, economic substance rules, registers, CRS and everything that has to be declared at home.
What is an offshore company in plain terms, and what counts as one in 2026
An offshore company is a company registered in a country that levies little or no tax on profits earned abroad and asks for lighter reporting than Europe does. The word says it: the business is run off the shore where the company is registered. There is nothing illegal about the company itself. What is illegal is using it to hide income from the tax authority of the owner's own country.
In Russia the term has an official meaning. The Ministry of Finance keeps a list of offshore zones (Order No. 86n of 5 June 2023), and it is longer than most people expect: around 90 countries and territories. It includes the classics such as the BVI, Seychelles, Belize, Mauritius and Saint Kitts and Nevis, but also Cyprus, Malta, Panama and even the United States, the United Kingdom, Poland and Slovenia. In Russian usage, offshore is a tax label rather than a beach.
The UAE has been taken off that list: the change was made by Ministry of Finance orders of 22 December 2025 and applies from 1 January 2026. The list matters mainly to Russian companies, because dividends from a company in a listed offshore zone do not qualify for the 0% rate under Article 284(3) of the Russian Tax Code.
Internationally, offshore jurisdictions are usually recognised by three traits: zero or low tax on foreign income, no requirement to do anything locally, and very little information about owners. Since 2019 the last two have faded considerably. Economic substance laws and government beneficial ownership registers have arrived, and banks have learned to ask questions that a shell company cannot answer.
How much does it cost to set up an offshore company: BVI, Seychelles, Belize, Mauritius, UAE and Nevis
Government fees in offshore centres are still modest, from USD 130 to incorporate in Seychelles to USD 2,600 a year for a Mauritius licence. Most of the cost goes not to the state but to mandatory infrastructure: a registered agent (a licensed local firm without which the state will not register a company or correspond with it), a registered address, reporting and the bank. The table shows only payments to the state and the mandatory rules for 2026.
| Jurisdiction and form | Government fee: incorporation and annual | Corporate tax | Beneficial ownership register | Economic substance | Best suited to |
|---|---|---|---|---|---|
| BVI, BVI Business Company | USD 550 and 550 (up to 50,000 shares), USD 1,350 and 1,350 (more) | None | Filed with the state registry within 30 days, 10% threshold; legitimate interest access since 1 April 2026 | 2018 Act, 9 relevant activities; lighter test for pure holding companies | Holding company, joint venture, deals with foreign partners |
| Seychelles, IBC (International Business Company) | USD 130 and 140 (fee schedule of the Seychelles Financial Services Authority, FSA) | Foreign income generally not taxed; passive income of companies in multinational groups only with local substance | Central closed database (2020 Act) | Filing to the tax authority on whether the company is in scope | Small trading or service business on a limited budget |
| Belize, company under the 2022 Act | Calculated for the specific articles | Since 2020 foreign income is exempt only with economic substance | Kept by the registered agent and passed to the registry's closed database | 2019 Act | Those who care about price and accept strict banks |
| Mauritius, GBC (Global Business Company) | Processing fee USD 600, licence USD 2,600 a year | 15%, partial exemption for some foreign income | Filed with the Registrar of Companies | Two resident directors, main bank account and accounting records in Mauritius, audit | Investment into Africa and India, holding with real management |
| Mauritius, Authorised Company | USD 600, then USD 1,400 a year plus USD 65 to the Registrar | Tax resident elsewhere, pays no Mauritian tax on foreign profit | Same | Management must be outside Mauritius | Trading and services outside Mauritius |
| UAE, RAK ICC international company (the Ras Al Khaimah registry) | ~$890, renewal ~$1,100 | 9% on profit above $110,000 | Under the RAK ICC 2019 rules: owners from 25%, register held by the agent, open to the regulator | Rules abolished from financial year 2023, corporate tax applies instead | Holding company for assets, including UAE property |
| Nevis, corporation or LLC | USD 300 plus USD 20 for the certificate, USD 300 a year | New companies since 2019 have no automatic exemption | Kept by the registered agent | Depends on where the company is managed | Holding assets, asset protection |
The currencies of Nevis and the UAE are pegged to the US dollar, so these dollar figures are stable. Agent and bank fees come on top of every figure, and in the BVI there are also filing fees for the registers. Country details are on our pages for company registration in the BVI, in Seychelles, in Mauritius and in the UAE.
Fees start at $130, a missed CFC notice costs about USD 5,900
No offshore registry accepts a company without a licensed registered agent, and the agent only files. Mistakes cost more than the fees: a bank refuses a company with no clear business purpose or source of funds documents, the BVI economic substance report goes in late and the company is fined or struck off, and Russian CFC notices miss the deadline. Murblz support removes these risks: we match the jurisdiction to the task and the bank before registration, prepare documents through the registered agent, assemble the bank file and handle reporting and notices. We guarantee professional work and a transparent process, and in most cases a result on the first filing.
Registration with Murblz on the basic package starts from $2,800 in Seychelles, $3,600 in Belize and $4,200 in the BVI; the total depends on the jurisdiction, nominee services and the bank, and a manager will calculate it in the chat.
How to set up an offshore company step by step
Registration is the shortest part of the whole story. More time goes into the registered agent's checks, the bank, and the step people tend to remember last: filings with the tax authority of the country where the owner lives. The main route looks like this.
- Purpose and tax residence. Before picking an island, answer three questions: what the company will do, where money will come from and go to, and which country treats the owner as a tax resident. Everything else depends on the answers, including whether an offshore company is needed at all. Offshore jurisdictions are compared with EU, UAE and Asian options in our guide where to set up a company in 2026.
- Jurisdiction and legal form. Holding structures usually go to the BVI or RAK ICC, trading and service businesses should think about the bank before the tax rate, and investment into Africa and India points to Mauritius.
- Agent due diligence. The agent runs KYC (know your customer): passport, proof of address, a description of the business, the source of funds. Politically exposed persons and clients from higher-risk countries get deeper checks. The agent may refuse without giving reasons. How to prepare source of funds evidence is covered in our article on proving the source of funds.
- Incorporation. The agent files the memorandum and articles of association and obtains the certificate of incorporation. A director is appointed straight away.
- Registers. In the BVI a new company files its register of beneficial owners, along with its registers of directors and members, with the Registry of Corporate Affairs within 30 days. Until the beneficial ownership register is filed the company may not start business, and it cannot get the certificate of good standing that banks ask for.
- Bank pack. Apostilled corporate documents, a certificate of good standing, a business plan, contracts with counterparties.
- Bank account. A separate and often the longest stage, covered below.
- Filings at home. A Russian tax resident notifies the Federal Tax Service of a stake in a foreign company within three months if the stake exceeds 10%.
- Annual upkeep. Renewal, annual return, economic substance report, controlled foreign company (CFC) notice. An offshore company is like a cat: it needs looking after every year, even when it does nothing at all.
The mandatory deadlines are easiest to track in one table. Missing any of them costs money, and in the BVI it can end with the company being struck off the register.
| What to do | Where | Deadline | Consequence of missing it |
|---|---|---|---|
| File the beneficial ownership register (10% threshold) | BVI, Registry of Corporate Affairs | 30 days after incorporation and 30 days after any change | No business allowed, penalties, strike-off |
| Pay the annual government fee | BVI | By 31 May (companies incorporated January to June) or by 30 November (July to December) | Penalties, then strike-off |
| File the annual return with financial information with the agent | BVI | 9 months after the financial year end | Penalties, strike-off |
| File the economic substance report | BVI, International Tax Authority (ITA) | 6 months after the end of the financial period | Penalty of USD 5,000 to 20,000 for a first breach |
| Renew the licence | Mauritius, Financial Services Commission (FSC) | Annually on the due date | Paying 3 to 6 months late doubles the bill: USD 5,200 instead of 2,600 for a GBC |
| Notify the Federal Tax Service of a stake in a foreign entity | Russia | 3 months from the date the stake exceeded 10% or changed | about USD 590 per entity |
| File the CFC notice | Russia | Individuals by 30 April, companies by 20 March of the following year | about USD 5,900 per CFC |
| Notify the Federal Tax Service of a personal account opened abroad | Russia | 1 month after opening | Fine under Article 15.25 of the Code of Administrative Offences |
How to open an offshore bank account and where companies actually bank
An offshore company almost never banks where it is registered. Small islands have few banks, and they mostly serve local customers. So a BVI company usually holds its account in another country, and that bank decides whether the structure has a life beyond its certificate of incorporation.
Mauritius is the exception: under section 71 of its Financial Services Act a Global Business Company keeps its principal bank account in Mauritius. Elsewhere the choice is wider: banks and payment institutions in the UAE, Hong Kong, Singapore, Switzerland, Cyprus and other financial centres. How the process works in Hong Kong, where banks are especially demanding, is explained in our article on business accounts in Hong Kong.
What a bank wants to see from an offshore company in 2026:
- A clear business model: who the customers and suppliers are and why the company is registered where it is.
- Contracts and invoices, not a promise that they will appear once the account is open.
- Evidence of the owner's source of funds and tax residence.
- A link to real activity: staff, an office, or at least management in the country where the account is opened.
- A clean record: for a BVI company the bank will factor in the FATF grey list and dig deeper.
Russian citizens and residents face an extra restriction. Under Article 5b of EU Regulation No 833/2014, EU banks may not accept deposits above $120,000 per bank from Russian citizens and residents, or from companies outside the EU that they own by more than 50%. Putting an offshore company between the owner and the bank does not help, because the rule covers such companies explicitly. Citizens of the EU, the EEA and Switzerland, and holders of residence permits there, are exempt.
The practical lesson: agree with the bank first, register the company second. Doing it the other way round is like buying a sofa that will not fit through the door. More on banks and checks in our guide how to open an account with a foreign bank, and we match companies with banks through our business accounts service.
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Economic substance: when an offshore company needs an office and staff
The BVI Economic Substance (Companies and Limited Partnerships) Act 2018 costs a shell company USD 5,000 to 20,000 for a first breach and up to USD 200,000 for a repeat one. For high-risk intellectual property companies the ceilings are USD 50,000 and 400,000. Rules like these appeared in every classic offshore centre at the urging of the EU and the OECD, and they share one idea: profit should sit where the work is actually done.
In the BVI the Act covers nine activities: banking, insurance, fund management, finance and leasing, headquarters, shipping, holding business, intellectual property, and distribution and service centres. A company carrying on one of them needs management, staff, spending and premises on the islands in proportion to the business. A pure equity holding company, which only owns stakes and receives dividends, faces a lighter test. The report goes through the agent to the International Tax Authority within 6 months of the end of the financial period. We handle this reporting through our BVI economic substance service.
| Jurisdiction | What is required | Key detail |
|---|---|---|
| BVI | Substance for 9 activities, annual report | Penalties from USD 5,000, risk of losing registration |
| Seychelles | From financial year 2024 every company tells the tax authority (Seychelles Revenue Commission) whether it is in scope | Passive foreign income of companies in multinational groups is exempt only with substance |
| Belize | Economic Substance Act 2019 | Since 2020 no foreign income exemption without substance |
| Mauritius, GBC | Two resident directors, principal bank account, accounting records and audit in Mauritius | The FSC checks that the company is managed from the island |
| UAE | Rules abolished for financial years ending after 31 December 2022 (Cabinet Decision No. 98 of 2024) | Replaced by 9% corporate tax; the 0% rate only for qualifying free zone persons with real substance |
| Nevis | Companies formed since 2019 have no automatic exemption | Tax status depends on where the company is managed |
A word on searches for an offshore company in Cyprus. Cyprus is an EU member with a full corporate tax, not an offshore centre in the classic sense, even though it appears on the Russian Ministry of Finance list. From 1 January 2026 the corporate tax rate there is 15% instead of 12.5%, under a reform passed by parliament on 22 December 2025. A Cypriot company works when it is genuinely managed on the island, and we have a dedicated company registration in Cyprus service.
Beneficial ownership registers and CRS: who will know who owns the company
Since 1 April 2026 the BVI has offered legitimate interest access to its beneficial ownership register. A request can come from anyone investigating or preventing money laundering, or carrying out customer due diligence under the anti-money laundering laws. Only owners of 25% or more are disclosed: name, month and year of birth, nationality and the nature of control. It is not a public register like the UK's, but it is no longer anonymity either.
The filing threshold in the BVI is lower: since 2 January 2025 anyone who owns or controls 10% of a company counts as a beneficial owner, down from 25%. Competent authorities, tax and law enforcement, see the full data. Seychelles has had a Beneficial Ownership Act since 2020: the information sits in a closed central database at the Financial Intelligence Unit. Nominee directors and nominee shareholders (people who appear on paper in place of the owner) do not get around these registers, because the register records the real owner.
The second channel is CRS. According to the OECD, 116 jurisdictions exchange information automatically and 13 more have committed to join in the coming years. All six offshore centres in our table take part. The bank holding the company's money identifies its controlling persons and reports the account to the tax authority of the country where the owner is tax resident. From 2026 there is also CARF (the Crypto-Asset Reporting Framework for exchanging information on crypto assets): the first countries collect data for 2026, while the BVI and the UAE will start exchanging by 2028.
CRS is neither a threat nor a reason to hunt for a country that does not exchange. It is a fact to plan around. The duty to declare the account, the company and the income rests with the owner in every case, even if a particular country does not send data. Which jurisdictions are still outside the exchange, and why that changes little, is covered in our article accounts without CRS.
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CFC rules and notices: what a Russian tax resident has to file
If the stake in an offshore company exceeds 10%, a Russian tax resident must notify the Federal Tax Service within three months. This is the notice of participation in a foreign entity (Article 25.14 of the Tax Code). If the stake exceeds 25%, or 10% where Russian residents together hold more than 50%, the company becomes a controlled foreign company (Article 25.13), and a CFC notice must be filed every year together with its financial statements.
Tax on the CFC's undistributed profit is due if that profit exceeds $120,000 for the year. Profit below the threshold is not taxed, but the notice is still filed, even if the company made a loss. There is an alternative, the fixed profit regime. Since 2025 the tax under it depends on the number of companies: about $59,000 a year for one CFC, about $120,000 for two, about $300,000 for five or more, with a minimum stay in the regime of 5 years.
| Obligation | When it arises | Deadline | Penalty |
|---|---|---|---|
| Notice of participation in a foreign entity | Stake above 10%, a change in it or an exit | 3 months | about USD 590 per entity |
| CFC notice with financial statements | Stake above 25% (or above 10% where Russians together hold over 50%) | Individuals by 30 April, companies by 20 March of the following year | about USD 5,900 per CFC |
| Tax on CFC profit | Profit for the year above $120,000 | In the personal income tax return (3-NDFL) for the following year | Late payment interest and penalties |
| Notice of a personal account opened abroad | Opening an account in the owner's own name | 1 month | Fine under Article 15.25 of the Code of Administrative Offences |
Residents of other countries should check their own rules: CFC regimes exist across the EU, in Kazakhstan, Ukraine and many other countries. We prepare the notices, calculate CFC profit and help choose the regime through our CFC and notices service.
What changed in offshore jurisdictions in 2025-2026
In eighteen months the rules changed in almost every popular offshore centre, mostly towards higher costs and more transparency. The sharpest price rise was in Mauritius, where the annual fee for an Authorised Company went from USD 350 to USD 1,400, four times as much.
| Date | What happened | What it means |
|---|---|---|
| 2 January 2025 | BVI: amendments to the BVI Business Companies Act, beneficial ownership and members registers filed with the state registry, 10% threshold | The anonymous BVI company is gone |
| 1 April 2025 | Nevis: new government fees, USD 300 to incorporate, USD 300 a year | More expensive, still cheap |
| 13 June 2025 | FATF put the BVI on the grey list | Banks worldwide factor it into their risk assessment |
| 1 January 2026 | Cyprus: corporate tax 15% instead of 12.5% | The European alternative got pricier |
| 1 January 2026 | Russia: the UAE removed from the Ministry of Finance offshore list | Russian companies can again receive UAE dividends at the reduced rate if the conditions are met |
| 17 February 2026 | EU updated its tax blacklist: American Samoa, Anguilla, Guam, Palau, Panama, Russia, Turks and Caicos, the US Virgin Islands, Vanuatu and Vietnam | None of the BVI, Seychelles, Belize, Mauritius, the UAE or Nevis is on it |
| 1 April 2026 | BVI: legitimate interest access to the beneficial ownership register | Data on owners of 25% or more can be requested for due diligence |
| 19 June 2026 | FATF kept the BVI on the grey list | Banks keep factoring it into their risk assessment |
| 1 July 2026 | Mauritius: GBC licence USD 2,600 a year instead of 1,950, Authorised Company USD 1,400 instead of 350 | Mauritius has left the budget segment for good |
The Mauritius regulator, the FSC, explained the increase plainly: processing fees had not changed since 2008 and annual fees since 2019. Honest, though the honesty does not make the invoice any lighter.
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Risks and pitfalls: who should not use an offshore company
The main risk for an offshore company in 2026 is not a tax audit but a bank that refuses it or closes the account six months later. There is no single bank blacklist: each bank keeps its own list of countries and risk signals. A company lands on it through a mix of the FATF grey list, the EU blacklist, sanctions and an opaque structure, and companies with no business, no staff and no clear money trail do not last long. Staying off such lists takes real activity, paperwork on the money and reports filed on time. What else to know in advance:
- FATF grey list. The BVI has been on it for a second year, and banks price that into their risk assessment. For an operating business this is a reason to look at other countries.
- EU restrictions for Russians. Deposits above $120,000 at an EU bank are also off limits to a company more than 50% owned by Russians.
- Russian offshore list. A Russian company receiving dividends from a listed offshore zone loses the 0% rate.
- CFC rules. Profit above $120,000 is taxed in Russia even if the money stays in the company's account.
- Missed deadlines. In the BVI a company can be struck off for unfiled registers and unpaid fees, and restoring it costs more than filing a form on time.
Who an offshore company suits: a holding company for stakes in businesses in several countries, a joint venture of partners from different jurisdictions, owning property or intellectual property abroad, international trade with real counterparties. For protecting family wealth a trust or foundation is sometimes the better tool: see our comparison trust or foundation.
Who it does not suit: anyone who wants to hide income from their own tax authority, Russians without an EU residence permit who need a large balance at a European bank, and businesses whose customers are all in one country, where a local company works better. If a BVI company already exists and banks keep saying no, moving it to the UAE without liquidation sometimes helps: redomiciliation from the BVI to RAK ICC.
How we help: offshore company, bank account and reporting end to end
We start with the purpose and the owner's tax residence, not with the island. We choose the jurisdiction, take the file through the agent's checks, register the company, file the registers, find the bank and prepare the Russian tax notices, so the structure is lawful both where it is registered and at home.
Company registration
Offshore, EU, UAE, Asia: we compare jurisdictions for the task and work out the full cost of ownership.
Learn more →BVI company
Incorporation, beneficial ownership and members registers, annual renewal and annual return.
Learn more →Seychelles company
An IBC with registered agent, address and preparation for the bank account.
Learn more →BVI economic substance
Whether the company is in scope, the report to the tax authority, substance on the islands.
Learn more →CFC and notices
Participation and CFC notices, profit calculation, choosing the fixed profit regime.
Learn more →Company bank account
A bank matched to turnover and jurisdiction, a document pack on the business and the source of funds.
Learn more →If the goal is a structure for the family as well as a company, see trusts and foundations, and for companies in Nevis and Belize see our pages on registration in Nevis and in Belize.
Get a free review of an offshore structure. Tell us what the company will do, where the owner is tax resident and where the account is needed. We will say which jurisdiction fits, what has to be filed with the registers and the tax authority, and whether an offshore company is needed at all.
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The finder compares offshore centres with jurisdictions where banking is easier: tax, presence and the first-year price with Murblz. For Russian tax residents it lists the notices to file.
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