Tax havens and tax administration

Glossary of offshore structures

Structure	Characteristics/features
Anstalt	German term for establishment. The founder establishes the anstalt with the transfer of assets, which become the property of the anstalt. A separate legal entity, with no shareholdings.
Foundation	A hybrid can be a trust or a company. This is a separate legal entity to which assets are transferred by the founder, which holds such assets for the benefit of a particular purpose.
International business company or offshore company	A common structure provided by many tax havens. May have ordinary share capital, be limited by guarantee or be a hybrid, for example a combination of ordinary shares and limited by guarantee. Typically not permitted to conduct business in the tax haven where it is registered (although this requirement has changed in some countries). Shareholdings are usually owned by nominee shareholders, often through a series of trusts to disguise ownership. Nominee directors. Offshore debit or credit card may be associated with the entity.
Offshore partnerships	Typically, an association of two or more people, formed by agreement to jointly pursue a common objective.
Offshore superannuation fund	May be a genuine superannuation fund set up in an offshore jurisdiction. In some cases, the offshore superannuation fund may be an offshore trust rather than a genuine superannuation fund.
Offshore trust	A trust set up in a tax haven. Essentially involves the transfer of legal ownership and control from a settlor to one or more trustees. The offshore trustee protects the identity of the beneficial owner of the trust assets. Often the beneficial owner will have in place 'a letter of wishes' to retain some control over the trust assets. Offshore trusts are often used to create another layer of secrecy in the ownership of offshore companies, such as international business companies.
Protected cell company, segregated portfolio company etc	The company contains separate or segregated cells that hold particular assets and liabilities, retained earnings etc.
Stichting	Formed under Dutch law. Can be described as a foundation. A separate entity, distinguished from its founders or directors. Not a tax haven entity but dealings with stichtings are sometimes routed through tax haven bank accounts.
Stiftung	German term for foundation. Often a family foundation. The founder establishes a stiftung with the transfer of assets. The actions of a stiftung are prescribed by the founding deed and acted upon by the administrators on behalf of beneficiaries. Capital is not divided into shares.