Really impressive insights throughout this thread, especially the points raised around DAC6 and the growing CFC complexities. It’s pretty clear that long-term planning inside the EU is becoming harder, not just because of tax hikes, but because of the unpredictable way governments enforce new rules. As mentioned earlier, even countries with “flat” tax regimes are under pressure, and tools like DAC6 only make things murkier, especially for advisors and intermediaries.
The comments on Hong Kong were also spot on. It used to be a go-to for clean offshore setups, but now the administrative burden, KYC scrutiny, and the risk of accidentally falling into onshore tax treatment make it a minefield, especially for anyone trying to use nominee directors or corporate layering. Hong Kong still has value as a banking hub, but as a jurisdiction for active company operations, it’s arguably lost a lot of its shine. That shift explains why we see more people looking into UAE, Georgia, or even lesser-known Caribbean options.
One thing I’m curious about: Has anyone here explored how DAC6 might affect offshore structuring outside the EU, say through UAE or Nevis entities, when EU-based UBOs or intermediaries are involved? Are reporting obligations still triggered, even if the structure itself is compliant in its own jurisdiction?
Also, there was a great mention of using layered company structures, holding companies within holding companies across multiple jurisdictions. Would be great to hear how people are dealing with banking within that setup, especially when most traditional banks now request full transparency all the way to the top-level UBO.
Would love to see a continuation of this topic with deeper dives into topics like territorial tax systems, intellectual property holding structures, and hybrid residency models.
