Go Global with Greenwolf

There is no single best country to set up a company. The right jurisdiction is the one that matches what the entity will actually do: sell into a market, hold investments, raise capital, own IP, run a fund or protect family wealth. Choose for the commercial reason first, then test tax, treaty access, substance and banking before you incorporate.

Key points

• Start with the job the company must do (market access, holding, fundraising, IP, funds, wealth or residency), then shortlist jurisdictions that are built for that job.

• Headline rates in 2026 run from no corporate income tax (Cayman, BVI) to 25% or more (UK, Spain, Monaco, Netherlands above €200,000), but the effective result depends on substance, treaties and the rules where the owners live.

• Groups with consolidated revenue of €750 million or more face a 15% minimum effective tax under the OECD GloBE rules in most of the jurisdictions on this page.

• Treaty benefits now sit behind the principal purpose test, and home-country CFC and management rules can pull offshore profits back to the founder.

• Banks often decide whether a structure is workable before any tax authority does, so plan the account opening alongside the incorporation.

How do you choose the best country to set up a company?

You choose a jurisdiction by starting with the commercial purpose of the entity, not the tax rate. A company that serves customers needs to sit near those customers; a holding company needs treaty access and a stable legal system; a fund vehicle needs investor familiarity. Tax follows once the role is clear.

We see six reasons to go abroad, and each points to a different shortlist:

• Market access: you need a local contracting party, staff or licence to sell. The USA, UK, UAE, India and the large EU markets lead here.

• Holding and fundraising: investors want a familiar parent and predictable courts. Singapore, the UK, Delaware, Luxembourg, the Netherlands and Cyprus are common.

• IP ownership: the entity that owns the IP must also control and fund its development, the DEMPE limit we cover in IP placement and the limits of tax-driven structuring. Ireland, Singapore, the Netherlands, Switzerland and the UK are typical.

• Funds: Cayman, Luxembourg, Mauritius, Ireland and Singapore are where institutional investors expect them.

• Wealth and succession: Liechtenstein, Switzerland, Monaco and the UAE for foundations and family offices.

• Founder residency: sometimes the founder moves first. Portugal, Spain, Italy, Greece, Andorra, Monaco and the UAE have residence-led regimes.

Cross-border expansion often develops through connected markets rather than a single jurisdiction. One such corridor is India–UAE–UK, where businesses increasingly combine operating, holding, market-access and founder-mobility considerations. We cover this step by step in our India–UAE–UK expansion guide. This page is the wider map.

Which countries does Greenwolf work in?

Greenwolf structures, incorporates and maintains companies in 24 jurisdictions. The table below compares them on typical use, 2026 headline corporate tax and the profile of business each one suits best. Rates are statutory headline rates; the effective rate for your company depends on its activities, reliefs and where its owners are resident.

One rule cuts across most of the table. Large multinational groups, meaning those with consolidated revenue of at least €750 million, are generally subject to a 15% minimum effective tax under the OECD GloBE (Pillar Two) rules, applied through domestic top-up taxes in jurisdictions such as the UAE, Switzerland, Hong Kong, Singapore, Ireland, the UK and EU member states.

Our explainer on GloBE and the end of arbitrage at scale sets out who is in scope. For mid-sized groups below that threshold, the headline rates still apply, but substance and anti-avoidance rules do the work instead.

Gulf and India: where most of our clients start

United Arab Emirates

The UAE is used for regional operating companies, Middle East and Africa headquarters, trading hubs and group holding companies, usually through free zones such as RAKEZ, DMCC or DIFC, or a mainland licence. Corporate tax is 9% on taxable income above AED 375,000, and free zone companies can apply 0% to qualifying income only if they meet every Qualifying Free Zone Person condition. Groups above €750 million pay a 15% Domestic Minimum Top-up Tax from 1 January 2025.

Ideal for: founders, investors and family offices building an operating or holding base with regional reach across Asia, Europe and Africa.

Read more: choosing between a Dubai free zone and a mainland company, the Qualifying Free Zone Person rules, and how to set up a UAE subsidiary of an Indian company.

India

India is the anchor jurisdiction for market access and delivery: a large domestic market, deep talent and, increasingly, global capability centres for foreign groups. Under the Income-tax Act, 2025, in force from 1 April 2026, domestic companies opting for the concessional regime pay 22% plus surcharge and cess (about 25.17% in total), while foreign companies taxed on Indian profits through a branch or permanent establishment face 35% plus surcharge and cess, per the Income Tax Department.

Ideal for: businesses scaling inside India, and international groups that want India as their delivery or operating base.

Read more: how to set up a company in India as a foreign business and our founder's view of building in India.

UK and Western Europe: market access, holding and wealth

United Kingdom

The UK is used for European market entry, holding companies, property and investment holding, and investor-facing parents, backed by one of the widest treaty networks in the world. Corporation tax is 25% on profits above £250,000, 19% on profits up to £50,000, with marginal relief between, as confirmed by GOV.UK.

Since 15 July 2026 the India–UK trade agreement (CETA) and the Double Contributions Convention are in force, which matters for Indian groups sending staff.

Ideal for: groups with UK or European customers and assets, global investors, and founders who want UK credibility behind cross-border deals.

Read more: why founders choose the UK and setting up a UK subsidiary of an Indian company.

Ireland

Ireland is an English-speaking, common-law gateway to the EU, used by SaaS, technology and IP-heavy businesses and by fund platforms. Trading profits are taxed at 12.5% and non-trading income at 25%, while groups within the €750 million GloBE threshold pay an effective 15%, according to Revenue.

Ideal for: SaaS and IP-rich companies, and investment structures that need EU substance and investor confidence.

Read more: our founders' guide to Ireland.

Netherlands

The Netherlands is used for EU distribution, licensing and intermediate holding companies, supported by a large treaty network and the participation exemption on qualifying dividends and gains. Corporate income tax is 19% on the first €200,000 of profit and 25.8% above, per the Belastingdienst. Conditional withholding taxes on payments to low-tax jurisdictions mean the Netherlands no longer works as a simple conduit.

Ideal for: royalty-driven and media businesses, and groups building an EU-facing corporate base.

Read more: incorporating in the Netherlands.

Luxembourg

Luxembourg is Europe's main hub for private equity, regulated funds and holding companies, with a deep bench of administrators, depositaries and directors. The combined corporate rate in Luxembourg City is 23.87% for 2026, according to PwC Worldwide Tax Summaries, and the participation exemption can shelter qualifying dividends and gains.

Ideal for: fund managers, family offices and cross-border investors who need regulatory credibility and flexible capital structures.

Read more: a practical guide to incorporating in Luxembourg.

Switzerland

Switzerland is used for private wealth, treasury and trading companies, and family holding structures, valued for legal stability and banking depth. The federal rate is 8.5% on profit after tax, and combined federal, cantonal and communal rates range from about 11.7% to 20.5% depending on canton, per PwC. Switzerland applies a 15% domestic minimum top-up tax to in-scope groups from 2024.

Ideal for: legacy-focused families, asset custodians and holders of large international portfolios who prioritise stability.

Read more: setting up in Switzerland.

Liechtenstein

Liechtenstein is used mainly for foundations, trusts and long-term family holding, within the European Economic Area and with a mature regulatory framework. Corporate income tax is a flat 12.5%, with a minimum annual tax of CHF 1,800.

Ideal for: high-net-worth individuals and family offices planning long-term asset protection and succession.

Read more: when and why founders choose Liechtenstein.

Monaco

Monaco is chosen for residence, family offices and succession planning, with no personal income tax for most residents (French nationals excepted). Companies earning more than 25% of their turnover outside Monaco pay 25% profits tax, while businesses trading only inside the Principality are generally outside it, according to MonEntreprise.mc.

Monaco has been on the FATF grey list since June 2024, which still slows banking and onboarding, so check its status before you plan around it.

Ideal for: ultra-high-net-worth individuals and family offices focused on long-term wealth preservation.

Read more: our guide to company formation in Monaco.

Andorra

Andorra combines a 10% corporate tax with no wealth or inheritance tax, a short drive from Barcelona and Toulouse. A 3% minimum effective corporate tax has applied since 1 January 2024, so reliefs can no longer reduce the bill to nil.

Andorra is low-tax rather than tax-free: capital gains are taxed at up to 10%. Residence became more expensive under Law 2/2026, and a UK–Andorra tax treaty has applied since April 2026. Andorran structures work only when the owner genuinely lives there and runs the business locally.

Ideal for: entrepreneurs and investors relocating within Europe who want a low-tax base close to major EU markets.

Read more: our guide to company formation in Andorra.

Southern Europe and the Mediterranean: EU access and residence-led regimes

Cyprus

Cyprus is an EU holding and IP jurisdiction with a participation exemption on most dividends and gains on shares, and a broad treaty network. From 1 January 2026 the corporate rate rose from 12.5% to 15%, and the deemed dividend distribution rule was abolished, as confirmed in EY's summary of the enacted reform. Substance in Cyprus, including local management, is what makes the holding company defensible.

Ideal for: international groups consolidating subsidiaries, IP holding, and founders who want EU credibility with efficient dividend flows.

Read more: our guide to company formation in Cyprus.

Malta

Malta keeps a 35% headline rate but, through its full imputation system, shareholder refunds can bring the effective tax on many trading profits to around 5%. Since Legal Notice 188 of 2025, companies can instead elect a final 15% tax without imputation, locked in for at least five years, as summarised by PwC.

Ideal for: digital businesses, international trading companies and globally mobile founders who need an EU-regulated base.

Read more: our guide to company formation in Malta.

Portugal

Portugal combines residence routes with a falling corporate rate: 19% for 2026, falling to 18% in 2027 and 17% from 2028, with 15% on the first €50,000 for SMEs, plus municipal and state surcharges. Companies licensed in the Madeira International Business Centre by 31 December 2026 can apply a 5% rate, within income ceilings tied to jobs and investment, until 31 December 2033 under the 2026 State Budget.

For individuals, the IFICI regime (often called NHR 2.0) replaced the old non-habitual resident scheme from 2024.

Ideal for: tech founders, digital professionals and groups looking for a compliant EU base with improving tax rates.

Read more: our guide to company formation in Portugal.

Spain

Spain gives access to a large EU market and is a natural bridge to Latin America. Corporate tax is 25%, while the ETVE holding regime can exempt 95% of qualifying foreign dividends and gains, subject to participation, comparable-taxation and substance conditions. Relocating employees may elect the Beckham regime, taxing Spanish employment income at a flat 24% up to €600,000 for the year of arrival and five more.

Ideal for: relocating executives, remote tech talent, and groups expanding into Spanish-speaking markets.

Read more: our guide to company formation in Spain.

Italy

Italy is a large consumer and industrial market, and also a residence destination for wealthy individuals. Companies pay IRES at 24% plus the regional IRAP tax, generally 3.9%. New residents from 1 January 2026 can opt for a flat €300,000 a year on foreign income (up from €200,000), with €50,000 for each family member, under the 2026 Budget Law. People who moved earlier keep the amount that applied when they arrived.

Ideal for: wealthy individuals relocating with family, legacy family offices, and companies targeting Southern European customers.

Read more: our guide to company formation in Italy.

Greece

Greece is used for real estate, shipping and residence-led planning, alongside its Golden Visa programme. Corporate tax is 22%. Under the article 5A non-domicile regime, qualifying new residents pay a flat €100,000 a year on foreign income for up to 15 years, plus €20,000 for each family member included, provided they invest at least €500,000 in Greece and were not Greek tax resident in 7 of the previous 8 years.

Ideal for: investors seeking EU residence through property, and high-net-worth individuals who want predictable tax on foreign income.

Read more: our guide to company formation in Greece.

Montenegro

Montenegro offers some of Europe's lowest rates in an EU candidate country that uses the euro. Corporate tax is progressive: 9% up to €100,000, 12% on profit from €100,000 to €1.5 million and 15% above, per PwC.

Accession talks are advanced, with EU membership targeted for 2028, and since January 2026 renewing a company-based residence permit generally requires the company to have paid at least €5,000 in taxes and contributions the year before.

Ideal for: start-ups, consultants and investors who want low rates in a growing market, for now outside the EU.

Read more: our guide to company formation in Montenegro.

Georgia

Georgia taxes companies on the Estonian model: profits are taxed at 15% only when distributed, so reinvested profits are not taxed. IT companies with Virtual Zone Person status pay no profit tax on IT services they create and supply to clients outside Georgia, though 5% withholding still applies to dividends.

International Company status, which needs a track record, local staff and an office, cuts the tax on distributions to 5% with no dividend withholding. Since 1 March 2026, foreign founders and employees also need a work permit.

Ideal for: IT and software businesses exporting services, and founders who want a low-cost digital base.

Read more: our guide to company formation in Georgia.

Asia-Pacific: regional headquarters and trade

Singapore

Singapore is the default regional headquarters, IP holding and investment hub for Asia, with strong courts and investor familiarity. Corporate tax is 17%, with partial exemptions on the first S$200,000 of income, and a 15% domestic top-up tax for large groups from 1 January 2025, per IRAS. Foreign-sourced income exemptions are narrower than many founders assume.

Ideal for: founders, fund managers and tech companies expanding across Asia and preparing for institutional investors.

Read more: Singapore incorporation for founders, why most founders misjudge Singapore's tax exemption rules and Singapore vs Dubai.

Hong Kong

Hong Kong is used for regional trading, sourcing and import-export companies, and as a gateway to mainland China. Profits tax is 8.25% on the first HKD 2 million of assessable profits and 16.5% above, and only Hong Kong-sourced profits are taxed, according to the Inland Revenue Department. The foreign-sourced income exemption regime now requires substance for passive income received offshore.

Ideal for: Asia-facing trading and digital businesses that want simple compliance and access to Chinese and APAC markets.

Read more: incorporating in Hong Kong.

Offshore and fund jurisdictions: capital, investment and ownership

Cayman Islands

Cayman is the leading jurisdiction for hedge funds, private equity funds and SPVs, and is familiar to institutional investors worldwide. There is no corporate income tax, but fund registration with the Cayman Islands Monetary Authority and economic substance rules apply to relevant activities.

Ideal for: larger fund launches, cross-border transactions and investment vehicles seeking global capital.

Read more: planning to build a company in the Cayman Islands.

British Virgin Islands

The BVI is widely used for holding companies, joint venture vehicles and investment SPVs because companies are quick to form and the corporate law is flexible. There is no corporate income tax, but beneficial ownership must be filed with the registered agent and economic substance rules apply to relevant activities.

Ideal for: holding companies, fund structures and international groups managing ownership across several jurisdictions.

Read more: BVI incorporation for founders and BVI vs Mauritius.

Mauritius

Mauritius is an established platform for investment into India and Africa, used for funds, holding companies and Global Business Companies. The corporate rate is 15%, and a partial exemption can reduce tax on certain qualifying income to an effective 3% where substance tests are met.

Since the 2016 protocol, India taxes capital gains on shares acquired after 1 April 2017, and a further protocol adding a principal purpose test was signed in 2024.

Ideal for: founders raising international capital, private equity investors, and groups managing FDI into India and Africa.

Read more: thinking about Mauritius.

Americas: market access and venture capital

United States

The USA is the largest single market and the default home for venture-backed companies, most often through a Delaware C corporation or, for smaller service businesses, a Wyoming or Delaware LLC. Federal corporate tax is 21%, with state taxes on top that range from nil in states such as Wyoming to over 11% elsewhere, per PwC.

Ideal for: founders entering the US market, SaaS companies, and start-ups preparing to raise from US investors.

Read more: the smart way for founders to set up in the US.

What is the best jurisdiction for a holding company?

The best jurisdiction for a holding company is one that has treaties with the countries where your subsidiaries sit, exempts the dividends and gains it receives, and is a place you can genuinely manage the company from. For Indian and UK founders, the UK, Singapore, the UAE, the Netherlands, Luxembourg and Cyprus are the usual shortlist.

A holding company earns its keep when it separates risk, makes fundraising cleaner or simplifies exits, as we explain in holding vs operating companies. If its directors actually meet in Mumbai or London, it may be resident there instead.

What mistakes do founders make when picking a jurisdiction?

The most common mistake is choosing a low headline rate and building nothing behind it. A company with no staff, no premises and no local decisions now fails economic substance tests, treaty tests and bank onboarding, usually all at once.

The four mistakes we see most often:

1. Low tax without substance. Since 2019, most offshore and mid-shore jurisdictions require core income-generating activities to happen locally. Our note on economic substance after 2022 shows why empty entities no longer survive.

2. Banks that say no. A structure that looks fine to a lawyer can still be refused by every bank you approach. We explain why banks challenge group structures before tax authorities do.

3. Assuming treaty benefits. Many of India's and the UK's treaties now include a principal purpose test that denies benefits where obtaining them was one of the main purposes of an arrangement. Read our principal purpose test guide before relying on one.

4. Forgetting home-country rules. UK CFC rules can tax a UK parent on low-taxed foreign profits, and India's place of effective management test can treat a foreign company run from India as Indian resident. See CFC rules and how founder behaviour shifts tax residency.

A fifth, quieter mistake is letting staff travel create a permanent establishment in a country where you never incorporated.

Can an Indian resident set up a company abroad?

Yes. Indian residents can own a foreign company under FEMA's Overseas Investment Rules, 2022, either through an Indian company making overseas direct investment or personally under the Liberalised Remittance Scheme, capped at USD 250,000 per financial year, according to the Reserve Bank of India.

Individuals can generally invest only in operating businesses, not financial services entities, and reporting is mandatory.

Which route is better depends on who should own the foreign company and how it will be funded. We compare them in how an Indian founder can fund an overseas company: ODI vs LRS.

How does Greenwolf run a multi-jurisdiction group?

We run a multi-jurisdiction group as one design, not a collection of separate incorporations. Each entity has a written role, a funding route, an intercompany pricing policy and a compliance calendar.

• Design first: a group chart showing who owns what, which entity contracts with customers, where staff and IP sit, and how cash moves up as dividends, service fees or royalties.

• Incorporation and banking: registered offices, local directors where needed, beneficial ownership filings, and the source-of-funds pack banks ask for before the first application.

• Intercompany flows: transfer pricing policies so each entity earns a return that matches its functions. Our article on transfer pricing in founder-led groups explains why informal arrangements become audit points.

• Ongoing compliance: accounts, returns and substance reports reviewed together each year, so one entity's change does not break another's position.

The Greenwolf view

The best international structures we see were designed around a commercial answer: this market needs a local company, this investor needs this parent, this family needs this kind of continuity. Tax follows functions, risks and substance, and the rules of 2026 (GloBE, the principal purpose test, CFC rules and bank due diligence) all test whether the structure matches reality.

So we start with questions, not countries. What will each entity do that no other entity can? Who will run it, and where will they live? Which investors or customers need to see it? How will profits move back, and at what tax cost?

For a ₹120 Cr Pune engineering exporter, the answer may be a UAE trading company and nothing else for three years. For a £15m UK software business raising a Series B, it may be a Delaware parent, a UK operating company and an Indian delivery centre.

Neither answer starts from the lowest rate in the table. Founders who live across several countries face these questions personally too, as we discuss in why the smartest founders no longer belong to one country.

Go global with a plan, not a postcode

If you are weighing where to set up your next entity, or need to make an existing group work across several countries, Greenwolf Advisors can map the commercial role of each company, model the tax consequences across jurisdictions, and then incorporate and run the structure. Speak with a Greenwolf strategist to start with the questions that matter.

This article is general information, not advice for a specific case.