In two royal decrees dated 23 August 2015, the Minister of Finance announced the legal entities that are deemed to be legal arrangements that must be reported in the tax payer’s tax return if he is the founder, an heir of the founder or a beneficiary and on which he must pay tax.
The first royal decree lists three legal entities within the European Economic Area.
| 1 Liechtenstein | – Anstalt
– Stiftung |
| 2 Luxembourg | – Société de gestion Patrimoine Familiale |
Even if the taxpayer were to prove that the entity paid more than 15% tax, he cannot avoid taxation.
The second royal decree lists all entities outside the European Economic Area that are deemed to be legal arrangements, but the taxpayer can prove that the entity paid more than 15% tax.
| 1 Anjouan (Union of the Comoros) | – International Business Company |
| 2 Antigua and Barbuda | – International Business Company |
| 3 Anguilla | – International Business Company |
| 4 Aruba | – Stichting Particulier Fonds |
| 5 Bahamas | – International Business Company
– Foundation |
| 6 Barbados | – International Business Company
– International Society with Restricted Liability |
| 7 Belize | – International Business Company |
| 8 Bermuda | – Exempt Company |
| 9 British Virgin Islands | – Company |
| 10 Brunei | – International Business Company |
| 11 Cayman Islands | – Exempt Company |
| 12 Cook Islands | – International Company |
| 13 Costa Rica | – Company |
| 14 Djibouti | – Exempt Company |
| 15 Dominica | – International Business Company |
| 16 Isle of Man | – Company |
| 17 French Polynesia | – Société |
| 18 Grenada | – International Business Company |
| 19 Guam | – Company |
| 20 Guatemala | – Fundación |
| 21 Guernsey | – Company – Foundation |
| 22 Hong Kong | – Private Limited Company |
| 23 Jersey | – Company
– Foundation |
| 24 Labuan (Malaysia) | – Offshore Company |
| 25 Libanon | – Companies that qualify for the offshore companies regime |
| 26 Liberia | – Non-resident company |
| 27 Macao | – Fundação |
| 28 Maledives | – Company |
| 29 Marshall Islands | – International Business Company |
| 30 Mauritius | – Global Business Company category 1
– Global Business Company category 2 |
| 31 Micronesia | – Company |
| 32 Monaco | – Fondation |
| 33 Montserrat | – International Business Company |
| 34 Nauru | – Company
– Other forms of company negociated with the government |
| 35 Netherlands Antilles | – Stichting Particulier Fonds |
| 36 New Caledonia | – Société |
| 37 Niue | – International business company |
| 38 Northern Mariana Islands | – Foreign sales corporation |
| 39 Palau | – Company |
| 40 Panama | – Fundación de interés privado |
| 41 Panama | – International Business Company |
| 42 Saint Kitts and Nevis | – Foundation
– Exempt Company |
| 43 Saint Lucia | – International Business Company |
| 44 Saint Vincent and the Grenadines | – International Business Company |
| 45 Salomon Islands | – Company |
| 46 Samoa | – International company |
| 47 San Marino | – Fondazione |
| 48 Sao Tomé and Principe | – International Business Company |
| 49 Seychellen | – International business company |
| 50 Switzerland | – Foundation |
| 51 Turks and Caicos | – Exempt Company |
| 52 Tuvalu | – Provident Fund |
| 53 United Arab Emirates | – Offshore Company |
| 54 USA State of Delaware State of Wyoming |
– Limited Liability Company – Limited Liability Company |
| 55 US Virgin Islands | – Exempt Company |
| 56 Uruguay | – Sociedad Anónima Financiera de Inversión |
| 57 Vanuatu | – Exempt Company |
| 58 Vanuatu | – International company |
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