The IBC is dead: what Cayman, BVI, Mauritius, Belize and Seychelles sell now
Cayman, BVI, Mauritius, Belize and Seychelles compared on substance, ownership registers, banking, treaties and grey lists. Only one still has a tax story.
Senior writerSeptember 20267 min readEvery offshore brochure still says "IBC" somewhere, usually next to a palm tree. The International Business Company — the ring-fenced, tax-exempt, nobody-knows-who-owns-it vehicle of the 1990s — no longer exists in any of the five jurisdictions people actually search for: Belize repealed its IBC Act in 2022, Seychelles kept the name and deleted the exemption, the BVI retired the term two decades ago, Cayman never used it, and Mauritius replaced its two-tier global business regime in 2019.
What you buy in 2026 is a plain company with a foreign address, a substance filing, an ownership record someone official can read, and a bank account that may or may not materialise. The five differ in compliance stack, not in secrecy.
What an "IBC" actually is now
Belize removed the tax and duty exemptions from its IBC Act from 1 January 2019, then in 2022 passed a single Companies Act (No. 11 of 2022) that repeals and replaces both the IBC Act and the domestic Companies Act; every entity had to re-register. There is no Belize IBC any more, only a Belize company, which may trade locally and is taxed on Belize-source income. Our Belize tax profile has the domestic picture.
Seychelles went territorial from 1 January 2019, deleted the tax-exemption clause from its IBC Act and let IBCs trade locally; the label survived, the privilege did not. See Seychelles taxes.
The BVI has run "business companies" under its 2004 Act for twenty years; the vehicle still pays no BVI income tax, but since 2 January 2025 its owners are filed with the registrar at a 10% threshold. Details in our BVI tax profile.
Cayman never sold an IBC. It sells the exempted company, no direct taxation and a regulator institutional counterparties recognise; Cayman taxes explains how a place with no tax code charges you at the border and the registry instead.
Mauritius abolished the GBC1/GBC2 split; today there is the Global Business Company — tax resident, 15% headline rate, treaty access — and the Authorised Company, managed and controlled outside Mauritius, not treated as tax resident and without treaties. Mauritius taxes has the rate card.
The five, side by side
| Cayman Islands | BVI | Mauritius (GBC) | Belize | Seychelles | |
|---|---|---|---|---|---|
| Tax on foreign profits | None | None | 15%; 80% exemption on qualifying income with substance, so about 3% | Belize-source income only (business tax); exemption clause repealed 2019 | Territorial since 2019 |
| Economic substance | Since 1 January 2019 | Since 1 January 2019 | Condition of the exemption | 2019 Act | Business Tax Act substance tests (no standalone act) |
| Who sees the owners | Authorities; legitimate-interest applicants since 28 February 2025 | Authorities; legitimate-interest policy of June 2025, being phased in | Filed with the registrar; authorities | Filed with the registrar; authorities | Resident agent; central database |
| Double-tax treaties | None of note | None of note | About 45; MLI since 2020 | Mostly CARICOM, plus a few bilaterals | About 29 in force |
| EU list, February 2026 | Not listed | Annex II | Not listed | Annex II | Removed from Annex II |
| FATF grey list | Off since October 2023 | On since June 2025 | Off since October 2021 | Not listed | Not listed |
| CRS reporting since | 2017 | 2017 | 2018 | 2018 | 2017 |
Economic substance: the same test, five accents
Four of the five adopted substance legislation in 2018–2019 because the EU Code of Conduct Group told them to; Seychelles wrote substance tests into its Business Tax Act instead. Either way, a company carrying on a "relevant activity" — holding, financing, intellectual property, headquarters, distribution, shipping, fund management — must show core income-generating activity where it is incorporated: people, premises, expenditure, decisions.
Cayman and the BVI give pure equity holding companies a reduced test — meet your filing obligations and keep adequate premises and people for holding shares — which is why the passive holdco still works there. Mauritius made substance the price of the 80% exemption: no Mauritian core activity, no exemption, 15% on everything.
A zero-tax company whose only decision-maker sits in Munich is, for tax purposes, a Munich company. Substance rules did not create that problem; they removed the excuse.
Beneficial ownership: the register is a question of who may ask
Cayman's model is the most formal: since 28 February 2025 a journalist, an academic researcher or a civil-society body fighting money laundering can apply, pay a fee and receive the information for a named legal person; searches by owner name are not allowed. The BVI is reaching a similar place by a different road: owners are filed at 10%, competent authorities see everyone at 25% and above, and the June 2025 access policy will let anyone with a legitimate anti-money-laundering purpose request that slice, with the company notified and able to object, once a transitional period ends.
Seychelles keeps the register at the resident agent and feeds a central database; Belize and Mauritius file beneficial-ownership information with their registrars. The privacy difference between the five is measured in the number of forms an investigator fills in, not in whether he gets an answer.
Banking: the bottleneck the formation agent does not control
A BVI or Cayman company has no natural home bank; you take it to Singapore, Zurich or Dubai and ask, and compliance teams there read the FATF list and the EU list before your business plan.
That makes the BVI's June 2025 grey-listing expensive in a way zero tax cannot offset: enhanced due diligence at every serious bank until FATF relents. Cayman went through exactly this from February 2021 to October 2023 and is now on the other side, which — with a domestic banking sector built around funds — is the biggest practical argument for Cayman over the BVI today. Mauritius has real banks that want global-business clients. Belize and Seychelles have local banks, but, my view, assume the company will bank elsewhere, and that elsewhere will ask why you chose Belize.
Treaties: Mauritius against everyone
Cayman and the BVI have no double-tax treaty network worth the name — irrelevant for a fund vehicle, whose investors are taxed at home; fatal for a holding company sitting on operating subsidiaries in India, Kenya or France, where dividends and interest come up at full withholding.
Mauritius has around 45 treaties, most covered by the multilateral instrument (in force for Mauritius since February 2020), which imports a principal-purpose test. Seychelles has around 29 in force, but no substance-linked partial exemption and no comparable banking sector. Mauritius is the only one of the five with a tax story that survives contact with a treaty partner — and only if you staff it.
The European owner: CFC and CRS make the choice for you
If you are tax resident in an EU member state, the anti-tax-avoidance directive's controlled-foreign-company rule has applied since 2019: low-taxed profits of a controlled subsidiary are attributed to you at home, and the UK's version is no kinder. CRS closes the other door: all five have exchanged account information automatically since 2017 or 2018, so the bank holding the company's cash reports the controlling persons to their country of residence every year. A zero-tax BVI holdco owned from Amsterdam or Milan does not reduce tax; it relocates the filing and adds a disclosure. The arithmetic differs for a resident of a territorial or no-CFC jurisdiction — the UAE, say — and that is who still uses these companies rationally; see the residence routes for Cayman, the BVI, Mauritius and Seychelles if you plan to move too.
Verdict
Cayman is for funds, SPVs and anything with institutional investors or lenders: the dearest of the five to run and the only one nobody has to explain to a counterparty. Not for a one-person holdco, which pays for a reputation it will not use.
The BVI remains the default wrapper for joint ventures and holding structures, and its company law is excellent; until FATF removes it from increased monitoring, expect banking friction.
Mauritius is the only choice with a live tax argument — Africa- and Asia-facing holding, real staff, roughly 3% on qualifying income; as a brass plate it is a 15% company with paperwork.
Belize: the IBC is gone, the exemption is gone, and the jurisdiction sits on Annex II. I cannot construct a case for a new incorporation.
Seychelles is the cheapest, and the February 2026 exit from Annex II is genuine progress; but cheap incorporation plus difficult banking is a doorstop, not a structure.
If you are European-resident and the goal is tax, none of the five does the job any more. If the goal is a clean legal vehicle for a real cross-border business, pick by banking and counterparty acceptance: Cayman first, Mauritius if treaties matter, the BVI once its grey-listing ends.
The full, dated reference for this: Services.
Frequently asked
Is a BVI company still tax-free in 2026?
In the BVI itself, yes: a BVI business company pays no BVI income tax, capital gains tax or withholding tax on its profits. What has changed is everything around that. Since 1 January 2019 companies carrying on a relevant activity must meet economic-substance requirements policed by the International Tax Authority. Since 2 January 2025 beneficial owners holding 10% or more must be filed with the registrar, and a legitimate-interest access policy published in June 2025 provides for outside parties with an anti-money-laundering purpose to request information on owners at 25% and above, with the company notified and able to object; that access is being phased in after a transitional period. The BVI was also placed under FATF increased monitoring in June 2025. And if the owner is tax resident in the EU or the UK, controlled-foreign-company rules will generally attribute the company's low-taxed profits to the owner at home. Tax-free at the company level is not the same as tax-free for you.
Does the Cayman Islands have a public register of beneficial owners?
Not a public one in the sense of an open searchable website. Cayman's Beneficial Ownership Transparency Act consolidated its earlier rules, and the Legitimate Interest Access Regulations commenced on 28 February 2025. Under them, law enforcement and competent authorities have full access, while certain members of the public — journalists, bona fide academic researchers and civil-society organisations working against money laundering and related crime — can apply to search the register for a named legal person on payment of a fee and on showing a legitimate interest. Searches can only be made by company name, not by the name of an individual, and separate access-restriction regulations protect people who face a serious risk of harm from disclosure. Unsuccessful applicants are told the reasons in writing.
What tax does a Mauritius Global Business Company pay?
The headline corporate rate in Mauritius is 15%. A company holding a Global Business Licence is tax resident and pays that rate, but qualifying categories of income — including foreign dividends and interest and income from certain licensed financial activities — attract a partial exemption of 80%, bringing the effective rate on that income to roughly 3%. The exemption is conditional on substance: the company must carry out its core income-generating activities in Mauritius, employ an adequate number of suitably qualified people directly or indirectly, and incur expenditure proportionate to its activity. A Mauritius GBC can also claim credit for foreign tax actually paid. The separate Authorised Company must have its central management and control outside Mauritius, is not treated as tax resident and has no access to the treaty network.
Can you still form an IBC in Belize?
No. Belize amended its International Business Companies Act, with effect from 1 January 2019, to remove the exemptions from taxes and duties and to end the ring-fencing that stopped IBCs dealing with Belizean residents; economic-substance legislation followed in 2019. In 2022 Belize went further and enacted a single Companies Act (No. 11 of 2022) that repealed and replaced both the old domestic Companies Act and the IBC Act. Entities registered before 28 November 2022 had to re-register on the new Online Business Registry System to keep operating. What you can form today is a Belize company under the 2022 Act, administered by the Belize Companies and Corporate Affairs Registry; foreigners without a Belize social security number must use a licensed registered agent. Belize remains on the EU's Annex II watch-list as of February 2026.
Is Seychelles still on the EU blacklist?
No. Seychelles has been on and off the EU's lists for years — it sat on Annex I, the blacklist proper, in 2020 and again in 2023 — but in the February 2026 update the Council removed Seychelles from Annex II, the watch-list of jurisdictions that have committed to reforms, after it achieved compliance with the international standard on exchange of information on request. Seychelles is not on the FATF list of jurisdictions under increased monitoring either. Domestically, Seychelles moved to a territorial tax system from 1 January 2019 and removed the tax-exemption clause from its IBC Act, so an IBC is now simply a company that is taxed on Seychelles-source income and generally not on foreign-source income. Beneficial-ownership registers are kept at the resident agent and feed a central database available to competent authorities.
Will an offshore company hide money from my home tax authority?
Not any of these five. Cayman, the BVI and Seychelles began automatic exchange of financial account information under the OECD Common Reporting Standard in 2017; Belize and Mauritius followed in 2018. A bank holding the company's account identifies the controlling persons and reports them to their jurisdiction of tax residence every year. Separately, all five keep beneficial-ownership information that is available to their own competent authorities and, on request, to foreign tax authorities under exchange-of-information agreements. If you live in an EU member state, the anti-tax-avoidance directive's controlled-foreign-company rule has applied since 2019 and attributes the low-taxed profits of a controlled company to you at home; the UK has an equivalent regime. An offshore company can still be a sensible legal vehicle for a genuine business. As a hiding place it stopped working around a decade ago.
Sources (7)
Fifteen years on tax, trusts and succession; writes the pieces the category would rather she didn't.
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