Guides/Countries with 0% corporate tax
Guide · 8 jurisdictions · 2026

The company pays 0%. The question is whether you do.

Eight jurisdictions offer a route to 0% in 2026, but only four are unconditional. The rest depend on where your revenue comes from, how big you are, or whether you ever take the money out.

8
Jurisdictions
At 0% on some or all corporate profit
4
Unconditional
The rest depend on income type or size
5
Substance tests
Every ESR regime asks the same five questions
Read this before you go any further

The era of "set up a shell in the Caymans and pay nothing" ended around 2018. Three things killed it: the OECD's BEPS project, the Common Reporting Standard forcing automatic exchange of banking data, and the Economic Substance Acts that every major offshore centre adopted between 2018 and 2020.

A 0% company in 2026 is legal only if it is real, an office, employees and revenue-generating activity in the jurisdiction. Founders routinely lose more to back-taxes and penalties than they ever saved.

Before you shortlist a jurisdiction

Where are you personally tax resident?

Taxed anywayGILTI / NCTI and Subpart F

A 0% company does almost nothing for you while you remain a US person.

US shareholders are taxed on most foreign subsidiary earnings above a routine return on tangible assets. The 2025 tax act renamed GILTI to net CFC tested income and cut the deduction from 50% to 40%, raising the effective rate from roughly 10.5–13.1% to about 12.6–14% from 2026. Citizenship-based taxation means moving abroad does not end the obligation, only expatriation or the Foreign Earned Income Exclusion changes the arithmetic, and the latter covers salary, not corporate profit.

Regime
NCTI (ex-GILTI) + Subpart F
Effective rate
~12.6–14%
Escapes by moving?
No, citizenship-based
General guidance, not advice. CFC outcomes turn on control percentages, activity type and treaty position.

The eight, side by side

Usable todayConditionalHard in practice
JurisdictionCorporate taxSubstanceSetup costPractical verdict
UAE free zones
Qualifying free zone person
0% / 9%Yes, ESR$5,000+The only zero with tier-one banking and 140+ treaties.
Estonia
OÜ, retained profits
0% / 22%Minimal€265Not a haven, a deferral. Zero reputational cost.
Cayman Islands
Exempted company
0%Yes, relevant activities$4,500–10,000Default for funds. Very hard to bank for trading.
British Virgin Islands
BVI business company
0%Yes, relevant activities$1,500–3,500Cheap holding vehicle. Not a trading company.
Bermuda
Exempted company
0% / 15%Yes$5,000+Still zero below €750m. Insurance capital of the world.
Bahamas
International business company
0%Yes$1,200–3,000Zero on paper, blocked at the bank in practice.
Vanuatu
International company
0%Yes, ESR$2,500–5,000Genuinely tax-free, genuinely hard to operate from.
Monaco
SARL or SAM
0% / 25%Residence€10,000+Zero only if three-quarters of revenue is local.
Six are pure offshore centres. The UAE is a hybrid, 0% on qualifying free zone income, 9% on the mainland. Estonia is not a haven at all: it defers tax rather than forgiving it.

Jurisdiction by jurisdiction

Most usable first
01
UAE free zones
The only 0% jurisdiction with full banking and treaty access

Since June 2023 the UAE levies 9% federal corporate tax on mainland profits above AED 375,000, but qualifying free zone persons earning qualifying income remain at 0%.

To qualify, an entity in one of the 40+ free zones must meet economic substance, derive income from other free zone persons or non-UAE customers, avoid excluded activities, and not elect out of QFZP status. DIFC, ADGM, DMCC and JAFZA are the most treaty-friendly.

Corporate tax
0% qualifying / 9%
Substance
Required (ESR)
Personal income tax
0%
Setup
$5,000+
For
+Treaty network of 140+ jurisdictions
+Tier-one banking and financial infrastructure
+Residency visa comes with the company
+0% personal income tax for residents
Against
−Qualifying income rules are strict and easy to fail
−5% VAT applies above AED 375,000 of supplies
−Annual audit required in many zones
02
Estonia
The only 0% system the EU and OECD endorse

Estonia is the outlier here: a full EU member, CRS-compliant, on no blacklist. Retained profits are taxed at 0% indefinitely; tax triggers only on distribution, at 22% since January 2025.

The 2% security-tax rise that would have taken the rate to 24% in 2026 was cancelled before it took effect. For founders reinvesting everything into growth, the effective rate is genuinely zero, with full single-market access and no substance drama.

Retained profit
0%
On distribution
22%
Substance
Minimal
Setup
€265
For
+Full EU membership and single-market access
+No reputational cost whatsoever
+0% on reinvested profit, indefinitely
+e-Residency allows fully remote management
Against
−Tax lands the moment you distribute
−Salary and fringe benefits taxed normally
−Not useful if you need cash out each year
03
Cayman Islands
The gold standard for fund structures, not for trading

No corporate income tax, no capital gains tax, no withholding, no payroll tax. The largest domicile globally for hedge funds, private equity vehicles and captive insurance, formed under the Companies Act as exempted companies.

The International Tax Co-operation (Economic Substance) Act 2018 requires real activity for entities carrying on relevant activities, banking, insurance, fund management, financing, IP, holding, shipping, headquarters. Budget roughly $1,500 in government fees plus $3,000–8,000 annually for agent and registered office.

Corporate tax
0%
Substance
Relevant activities
Setup
$4,500–10,000
Renewal
$3,000–6,000
For
+True 0% on corporate, gains and withholding
+Mature English common-law system
+Default jurisdiction for global funds
+No currency controls, USD-pegged
Against
−Reputational drag and grey-list history
−Banking for new companies is very difficult
−Substance rules bite on most active business
04
British Virgin Islands
The world's most common offshore company

The most numerous offshore incorporation globally, with over 400,000 active BVI business companies. Zero corporate tax, no capital gains, no withholding, governed by the BVI Business Companies Act 2004.

Since the Economic Substance Act 2018, relevant activities require local substance or the entity risks reclassification. Useful as a holding vehicle, joint venture company or single-asset SPV, not for live trading without real presence.

Corporate tax
0%
Substance
Relevant activities
Setup
$1,500–3,500
Renewal
$1,200–2,500
For
+Cheapest serious offshore jurisdiction
+Incorporation in 24–48 hours
+No public shareholder or director registry
Against
−Banking is extremely difficult
−Reputational drag on invoices and contracts
−Substance rules narrow the use cases sharply
05
Bermuda
Insurance capital of the world, now with a 15% tax for large groups

Historically 0% and still so for the vast majority of companies. In response to Pillar Two, the Corporate Income Tax Act 2023 introduced a 15% rate applying only to Bermuda-resident entities within multinational groups above €750 million of consolidated revenue, for fiscal years beginning on or after 1 January 2025.

Below that threshold Bermuda remains a genuine zero. It dominates insurance, reinsurance and captive structures, and the regulatory regime is the strongest of any jurisdiction on this list.

Corporate tax
0% below €750m
Large groups
15%
Substance
Required
Setup
$5,000+
For
+Top-tier insurance regulatory regime
+Strong reputation for captives and reinsurance
+English common law
Against
−15% now applies to groups above €750m
−High cost of living inflates substance costs
−Limited banking access for new entrants
06
Bahamas
Another common-law haven, still zero for now

No corporate income tax, no capital gains tax, no inheritance tax. International business companies are the usual vehicle, and the Bahamas enacted economic substance requirements in 2018 alongside its peers.

Banking is under particular stress: the Bahamas reports under CRS and local banks have de-risked to the point where new non-resident accounts are very hard to open. Best used today by Bahamian residents and substance-backed regional businesses.

Corporate tax
0%
VAT
10% domestic
Setup
$1,200–3,000
Renewal
$1,000–2,500
For
+No corporate, capital gains or inheritance tax
+Bahamian dollar pegged to USD
+English common law
Against
−Banking access is severely limited
−Historical blacklist appearances
−10% VAT applies domestically
07
Vanuatu
A true Pacific zero, with citizenship attached

No corporate income tax, no personal income tax, no capital gains tax, no inheritance tax, one of the few genuinely tax-free jurisdictions. International companies are governed by the International Companies Act.

Vanuatu also runs one of the fastest citizenship-by-investment programmes, from around $130,000. It is the most remote and least banked jurisdiction here, and spent several years on the EU list of non-cooperative jurisdictions before being removed, worth verifying its current listing status before you commit.

Corporate tax
0%
Personal income tax
0%
Substance
Required (ESR)
Setup
$2,500–5,000
For
+True zero across corporate, personal and gains
+Citizenship available by investment
+English common law
Against
−Remoteness limits practical operations
−Banking is severely limited
−Reputational risk from past listings
08
Monaco
Zero on local business only, and you have to live there

No personal income tax for residents other than French nationals, and 0% corporate tax for companies deriving more than 75% of turnover inside Monaco. Cross-border businesses, the typical SaaS or trading company, pay 25%, the same as France.

Monaco therefore suits high-net-worth individuals establishing personal residence, or genuinely local service businesses. Residence requires a substantial bank deposit and a rental contract in one of the most expensive property markets in the world.

Local business
0%
International revenue
25%
Personal income tax
0% non-French
Setup
€10,000+
For
+0% personal income tax for non-French residents
+Prestigious address and private banking
+Strong privacy and political stability
Against
−25% corporate tax on cross-border revenue
−Residence needs a large deposit and lease
−Very high cost of living

What substance actually means

Every jurisdiction on this list enforces some version of these tests. Failing them means penalties, information exchange with your home tax authority, and often reclassification of the company as tax resident somewhere else entirely.

Directed and managed locally
board meetings physically held in the jurisdiction, with a quorum of directors present, minutes recorded locally.
Adequate employees
at least one or more qualified employees, proportional to the income of the entity.
Adequate physical office
a real office, not a mailbox at a formation agent. Independent leases, utilities, and signage are expected.
Adequate operating expenditure
the entity must spend real money in the jurisdiction proportional to its income.
Core income-generating activities (CIGA)
the actual work producing income must happen locally, not be outsourced back to the shareholder's home country.
Pillar Two, briefly

A 15% global minimum effective rate applies to groups above €750m of consolidated revenue, enacted across the EU, UK, Japan, Korea and Canada from 2024–25. Below that threshold it does not touch you. Bermuda's new 15% tax exists because of it; the UAE's 9% regime was shaped by it.

Common questions

Who actually benefits in 2026

Fund Managers and Crypto Trading
Cayman Islands

Cayman Islands exempted companies remain the global default for hedge fund and private equity structures, especially master-feeder arrangements. The combination of 0% tax, flexible governance, and investor familiarity is unmatched. BVI is the second choice for smaller funds and crypto trading entities.

Operating Businesses with Substance
UAE free zones

UAE free zones. Genuine operations with UAE-based staff and customers qualify for 0% tax on qualifying free zone income, plus treaty access to 140+ jurisdictions, and 0% personal income tax for resident owners. See our UAE guide for the free zone selection framework.

Reinvesting Founders
Estonia

Estonia. If you plan to retain all profits for reinvestment over multiple years, Estonia's 0% on retained earnings is the single most efficient legitimate structure globally. Full EU access, zero substance drama, clean reputation.

High-Net-Worth Individuals
Monaco, UAE or Bahamas

Monaco, UAE, and Bahamas offer 0% or near-0% personal income tax for residents. Each requires a real residence move and often a substantial deposit or visa fee. Best explored with dedicated wealth planners rather than a generic formation agent.

Before you incorporate

A treaty-backed low rate usually beats a headline zero.

Once CFC attribution, substance costs and banking friction are counted, Singapore or a UAE free zone typically nets more than a pure haven. Model it before you file.

Tax calculatorCompare effective corporate rates across jurisdictionsCost estimatorSubstance has a price, see what the first year costsCountry comparisonPut two jurisdictions side by sideDocument checklistWhat you need to gather before you file

We email when a zero stops being zero

Bermuda introduced 15% in 2025. Others will follow. One email, no pitches.