Tax planning and optimisation through offshore companies

International tax planning is convenient to start with the business scheme and only then move to choosing the country of registration. The owner determines where the goods or services are sold, which company signs the agreement, where the assets are located and where available profit will be directed. The functions are then divided between operating, holding and investment companies, and a suitable business bank account is selected for each. This order makes it possible to build a structure that helps earn profit, finance new projects and keep the economics of the whole group clear.

First profit, then the company's country

An international business almost always has several points between which the economic result is distributed: the client's country, the supplier's country, the location of the team, the company that owns the asset and the owner's tax residence. Tax planning connects these elements in one model and shows where profit actually arises and how it can be used for the next project.

Therefore, the question "which offshore company is better" makes sense only after the transaction has been described. For an agency business, the commission agreement and the client's country are important. For trade, the supplier, warehouse, logistics and currency are important. For a software product, the software rights and development team matter. For investments, the asset, its country and the method of later sale matter.

Operating company

An operating company enters into agreements with clients, receives revenue and bears the main business expenses. It may be registered in the country of the main market or in an international jurisdiction convenient for foreign trade and payments. The choice depends on counterparties' requirements, the bank and the actual organisation of the business.

For such a company, a business bank account for current payments is especially important. It should support the business currencies, clear bank details for clients and payments to suppliers. If the company works with marketplaces or online sales, acquiring, marketplace payouts and multi-currency accounts are also taken into account.

Holding company

A holding company performs a different task: it owns interests in operating companies, receives dividends and directs capital to new projects. It is useful when the owner has several businesses or plans to buy a business. For a group within the EU, the application of the EU Parent-Subsidiary Directive and national participation regimes is calculated separately.

The holding company's business bank account is used for investment operations: dividends, purchase of shares, loans to subsidiaries and return of invested capital. Therefore, the bank is selected according to the investment model, not according to the criteria of an ordinary trading company's current account.

Company for intellectual property

If a significant part of the business value is connected with a trade mark, software, patent or another intellectual-property asset, the owner may place that asset in a separate company. This simplifies licensing to several group companies and makes it possible to account separately for development costs and income from use of the rights.

For tax purposes, the country of the rights owner, the countries of the users and the terms of the licence agreements are calculated. The company should have a clear business function and documents confirming ownership of the asset and its use within the group.

Investment company

Available group profit may be directed to a separate investment centre. Such a company acquires securities, interests in projects, real estate or other assets. As a result, operating risk is separated from long-term investment capital and the owner receives separate reporting on portfolio returns.

For an investment company, the bank, broker and ability to document the source of capital are especially important. If investments are financed by dividends from subsidiaries, the money-flow scheme is recorded in advance in company decisions and the business description for the bank.

Where to use an offshore company

A classic offshore company can be useful as an independent operating structure, owner of a foreign asset or participant in an international investment project. Its place in the structure is determined by the geography of the business and partners' requirements. For some operations, a simple company form and predictable annual cost are more important; for others, a European company or a local structure in the market country is preferable.

The terms of an offshore business bank account for a non-resident company are also determined by the actual payments. Depending on the task, this may be an international bank, a European payment system (EMI) or an online bank. The main point is to agree in advance the currencies, countries of counterparties and expected turnover.

How to calculate the real cost of the structure

The budget consists of more than registration. The calculation includes annual renewal, accounting and reporting, company address, director where required, bank, payment fees and professional support. For an investment group, broker costs, audit and transaction support are added.

After that, the tax result is calculated for each type of income: trading profit, dividends, interest, licence payments and capital gains. This calculation makes it possible to compare structures by the amount that remains available to the business after all company expenses.

Owner's tax residence

The final element of the model is the owner's tax residence. For a Ukrainian tax resident, a foreign company is analysed together with the controlled foreign company rules. It is convenient to take this into account when the structure is created: the financial year, accounting documents and reporting calendar are aligned with the owner's personal tax planning from the start.

In 2026, controlling persons in Ukraine file controlled foreign company reporting for 2025 together with the annual tax return. If the owner is only planning a new company, its accounting and reporting documents can be organised from the first operating period and unnecessary administrative work can be avoided later.

Working procedure

1. We determine the sources of revenue and main expenses.
2. We separate operating, holding and investment functions.
3. We select two or three countries for each key company.
4. We calculate taxes, annual expenses and bank fees.
5. We support opening business bank accounts and preparing the business description for the bank.
6. We register companies and prepare agreements between members of the group.

This order makes it possible to build the structure around profit and the business rather than around a catalogue of jurisdictions. As a result, the owner understands the purpose of each company and can easily explain it to a partner, accountant and bank.