Jurisdiction as a Strategy: How International Capital Structuring is Shifting in the New Economic Reality
A decade or two ago, choosing a jurisdiction to incorporate a company, fund, or holding structure often came down to rather pragmatic criteria: tax burden, administration costs, and the speed of legal entity creation. In professional circles, people often spoke of the "most efficient" or "most tax-neutral" jurisdiction, viewing it primarily as a technical tool to implement a business model.Today, this approach is rapidly losing its relevance.Recent years have demonstrated how quickly regulatory regimes, geopolitical conditions, and international trade rules can shift. OECD initiatives against base erosion and profit shifting (BEPS), the Automatic Exchange of Information (CRS), tightening economic substance requirements, sanction regimes, and skyrocketing compliance demands have fundamentally changed the very philosophy of international structuring.Under these conditions, a jurisdiction is no longer just a place of incorporation. It has increasingly transformed into a tool for managing legal, tax, and reputational risks. Today, the quality of the legal system, regulatory stability, international reputation, and access to financial infrastructure matter just as much as the tax rate...