Council Directive 2014/48/EUShow full title

‘ANNEX I Indicative list of categories of entities and legal arrangements which are considered to be not subject to effective taxation, for the purposes of Article 2(3)

1. Entities and legal arrangements whose place of establishment or place of effective management is in a country or jurisdiction outside the territorial scope of this Directive as defined in Article 7 and which is different from those listed in Article 17(2):

Countries and jurisdictions	Categories of entities and legal arrangements
Antigua and Barbuda	International business company
Anjouan (Comores)	Trust, governed by local or foreign law International business company
The Bahamas	Trust, governed by local or foreign law Foundation International business company
Bahrain	Financial trust, governed by local or foreign law
Barbados	Trust, governed by local or foreign law International business company International Society with Restricted Liability
Belize	Trust, governed by local or foreign law International business company
Bermuda	Trust, governed by local or foreign law Exempt company
Brunei	Trust, governed by local or foreign law International business company International trust International Limited Partnership
Cook Islands	Trust, governed by local or foreign law International trust International company International partnership
Costa Rica	Trust, governed by local or foreign law Company
Djibouti	Exempt company Trust, governed by foreign law
Dominica	Trust, governed by local or foreign law International business company
Fiji	Trust, governed by local or foreign law
French Polynesia	Société (Company) Société de personnes (Partnership) Société en participation (Joint venture) Trust, governed by foreign law
Grenada	International business company Trust, governed by local or foreign law
Guam	Company Sole proprietorship Partnership Trust, governed by foreign law
Guatemala	Trust, governed by local or foreign law Fundación (Foundation)
Hong Kong	Trust, governed by local or foreign law Private Limited Company
Kiribati	Trust, governed by local or foreign law
Labuan (Malaysia)	Offshore company Malaysian offshore bank, Offshore limited partnership Offshore trust
Lebanon	Companies benefiting from the Offshore company regime Trust, governed by foreign law
Liberia	Non-resident company Trust, governed by local or foreign law
Macao	Trust, governed by local or foreign law Fundação (Foundation)
Maldives	Company Partnership Trust, governed by foreign law
Northern Marianas Islands	Foreign sales corporation Offshore banking corporation Trust, governed by foreign law
Marshall Islands	Trust, governed by local or foreign law International business company
Mauritius	Trust, governed by local or foreign law Global business company categories 1 and 2
Micronesia	Company Partnership Trust, governed by foreign law
Nauru	Trust/nominee company Company Partnership Sole proprietorship Foreign will Foreign estate Other form of business negotiated with the Government
New Caledonia	Société (Company) Société civile (Civil company) Société de personnes (Partnership) Joint venture Estate of deceased person Trust, governed by foreign law
New Zealand	Trust, governed by foreign law
Niue	Trust, governed by local or foreign law International business company
Panama	Fideicomiso (Trust, governed by local law) and trust governed by foreign law Fundación de interés privado (Foundation) International business company
Palau	Company Partnership Sole proprietorship Representative office Credit union (financial cooperative) Cooperative Trust, governed by foreign law
Philippines	Trust, governed by local or foreign law
Puerto Rico	Estate Trust, governed by local or foreign law International banking entity
Saint Kitts and Nevis	Trust, governed by local or foreign law Foundation Exempt company Exempt Limited Partnership
Saint Lucia	Trust, governed by local or foreign law International business company
Saint Vincent and the Grenadine	Trust, governed by local or foreign law International business company
Sao Tomé e Principe	International business company Trust, governed by foreign law
Samoa	Trust, governed by local or foreign law International trust International company Offshore bank Offshore insurance company International partnership Limited partnership
Seychelles	Trust, governed by local or foreign law International business company
Singapore	Trust, governed by local or foreign law
Solomon Islands	Company Partnership Trust, governed by local or foreign law
South Africa	Trust, governed by local or foreign law
Tonga	Trust, governed by local or foreign law
Tuvalu	Trust, governed by local or foreign law Provident fund
United Arab Emirates	Trust, governed by local or foreign law Offshore company
State of Delaware (USA)	Limited Liability Company
State of Wyoming (USA)	Limited Liability Company
US Virgin Islands	Trust, governed by local or foreign law Exempt company
Uruguay	Trust, governed by local or foreign law Sociedad Anónima Financiera de Inversión
Vanuatu	Trust, governed by local or foreign law Exempt company International company

2. Entities and legal arrangements whose place of establishment or place of effective management is in a country or jurisdiction listed in Article 17(2), to which Article 2(3) applies pending the adoption by the country or jurisdiction concerned of provisions equivalent to those of Article 4(2):

Countries and jurisdictions	Categories of entities and legal arrangements
Andorra	Trust, governed by foreign law
Anguilla	Trust, governed by local or foreign law International business company
Aruba	Trust, governed by local or foreign law Stichting Particulier Fonds
British Virgin Islands	Trust, governed by local or foreign law Company
Cayman Islands	Trust, governed by local or foreign law Exempt company
Guernsey	Trust, governed by local or foreign law Company Foundation
Isle of Man	Trust, governed by local or foreign law Company
Jersey	Trust, governed by local or foreign law Company Foundation
Liechtenstein	Anstalt (Trust, governed by local law) and trust governed by foreign law Stiftung (Foundation)
Monaco	Trust, governed by foreign law Fondation (Foundation)
Montserrat	Trust, governed by local or foreign law International business company
Netherlands Antilles	Trust, governed by local or foreign law Stichting Particulier Fonds
San Marino	Trust, governed by local or foreign law Fondazione (Foundation)
Switzerland	Trust, governed by foreign law Foundation
Turks and Caicos	Exempted company Limited partnership Trust, governed by local or foreign law’.