I guess you are right, for most individuals and modest income earning businesses. I suppose these countries must be reviewed and assessed as an option, like all possible incorporation countries, according to your own purposes for opening the company, type/s of business, source/s of income, barriers, etc etc and overall objectives. These days we know BVI is off the FATF black and grey lists, but is still subject to punitive taxes and black list related problems in some countries. For example, businesses will still apply enhanced︀ customer due diligence and enhanced ongoing monitoring in any business relationship with a person established︁ in a former known high-risk third country or in relation to any relevant transaction where︂ either of the parties to the transaction is established in such a high-risk third country.︃ That alone is unwanted attention and hassles that many people prefer to avoid or simply︄ do not have the resources to manage. We know the BVI has no DTA's, so︅ for payments received from B2B transactions I guess that means most payments will have withholding︆ taxes applied in the source country. Also, I think some countries will apply higher WHT︇ to business transactions because BVI is a low / zero tax country. Some countries apply︈ severe penalty tax rates for funds going to countries such as the BVI. France still︉ includes the BVI on its black list, with some penalty tax rates even up to︊ 75% and can be higher like ~92% if social 'taxes' need to be paid as︋ well. So, like for every jurisdiction, there is much to consider and an experienced international︌ tax advisor for your type and model of business will be needed. For wealthy people︍ and big business no doubt the BVI will continue to have benefits.