Guide

Offshore Tax Havens in 2026: Low-Tax Jurisdictions for Gaming Companies After Pillar Two

By Gambling Consulting ExpertPublished Updated 3 min read

Short answer

The classic offshore tax haven still exists in 2026, but with three limits. The OECD Pillar Two rules impose a 15% minimum tax on groups with revenue of €750 million or more; economic substance laws require real activity where the company is based; and the EU list of non-cooperative jurisdictions brings sanctions. For gaming companies, the license, gambling duty and where management sits matter more than the headline 0% rate.

Low-tax and offshore jurisdictions for gaming companies in 2026

The 2021 version of this article listed ten offshore tax havens by headline rate. That list is still roughly right on rates, but much less useful: since then the 15% global minimum tax, economic substance laws and the EU tax blacklist have changed what a low-tax structure can achieve. This update explains the 2026 picture for gaming businesses. For a full table of rates, see our article on corporate tax rates in 2026.

Zero and low-tax jurisdictions in 2026

GroupJurisdictions
No general corporate taxAnguilla, Belize, British Virgin Islands, Cayman Islands, Turks and Caicos Islands, Vanuatu
0% for most companies, 15% for large multinationalsBahamas, Bahrain, Bermuda, Guernsey, Isle of Man, Jersey
Low single-digit or low-teens ratesHungary 9%, UAE 9%, Bulgaria 10%, Ireland 12.5%, Cyprus 15%, Gibraltar 15%

Source: Tax Foundation, 2025 survey; Cyprus and Gibraltar updated for their 2024–2026 increases.

Three rules that limit tax havens

1. The 15% global minimum tax

Under the OECD Pillar Two rules, multinational groups with consolidated revenue of €750 million or more must pay at least 15% on profits in every country. If a subsidiary pays less, a top-up tax is collected — increasingly by the low-tax jurisdiction itself through a domestic minimum tax, which is why Bermuda, Jersey, Guernsey and the Isle of Man now tax large groups at 15%.

2. Economic substance

Most offshore centers have economic substance laws requiring companies in relevant activities to be directed and managed locally, with adequate staff, premises and expenditure. A company with a local registered agent and nothing else risks penalties, strike-off and the exchange of information with its owners’ tax authorities.

3. The EU list of non-cooperative jurisdictions

The EU reviews its list of non-cooperative jurisdictions twice a year. Listed jurisdictions face defensive measures in member states, such as higher withholding taxes and denial of deductions, and banks treat them as high risk. Check the current list before choosing a jurisdiction.

What matters more for gaming companies

For a licensed gambling business, the headline corporate rate is often the smallest number in the model:

  • Gambling duty or GGR tax — from 0.15% of gross profit in Gibraltar to 40% Remote Gaming Duty in the United Kingdom;
  • License fees — from a flat €28,000 a year in Nevis to over €1.28 million a year in statutory charges in Romania;
  • Place of effective management — directors who manage from a high-tax country can bring the profits there;
  • Banking and payments — providers look at the license and substance, not just the tax rate.

Jurisdictions where license and tax line up

JurisdictionCorporate taxGambling chargeGuide
Isle of Man0% on most e-gaming income1.5% to 0.1% of GGY by bandIsle of Man
Malta35% headline, about 5% effective after refundsGaming tax on players in MaltaMalta
Gibraltar15%0.15% of gross profitGibraltar
Nevis0% on foreign-sourced GGR, subject to conditions€28,000 flat annual feeNevis
Kahnawà:keDepends on the company’s own jurisdictionNo GGR levyKahnawake

How Gambling Consulting Expert can help

We design the group structure around the license, gambling duty and substance requirements, form the companies through our company formation service and prepare the banking files. Contact us.

Frequently asked questions

Which jurisdictions still have 0% corporate tax?

Anguilla, the British Virgin Islands, the Cayman Islands, the Turks and Caicos Islands and Vanuatu, among others. The Bahamas, Bahrain, Bermuda, Guernsey, the Isle of Man and Jersey keep 0% for most companies but apply a 15% minimum tax to large multinational groups.

Does the global minimum tax affect small gambling groups?

Usually not directly. Pillar Two applies to multinational groups with consolidated revenue of at least €750 million in two of the previous four years. Smaller groups are mostly affected through substance rules, CFC rules and banking due diligence.

What are economic substance rules?

Laws in most offshore centers, adopted under EU and OECD pressure, that require companies carrying on relevant activities to be directed and managed locally, with adequate staff, premises and spending. A company that fails the test faces penalties and information exchange with the owners' tax authorities.

Where are gambling companies typically based for tax reasons?

Where a gaming license and favorable tax coincide: the Isle of Man (0% corporate tax on most e-gaming income), Malta (35% headline rate, about 5% effective after shareholder refunds), Gibraltar (15% with 0.15% duty) and Nevis (0% on foreign-sourced GGR, subject to conditions).

Can a 0% company be taxed elsewhere?

Yes. If it is effectively managed from another country, has a permanent establishment there, or its owners are subject to controlled foreign company rules, profits can be taxed in that country.

Legal and regulatory references

  1. Tax Foundation — Corporate Tax Rates around the World, 2025
  2. OECD — Global Anti-Base Erosion Model Rules (Pillar Two)
  3. Council of the EU — EU list of non-cooperative jurisdictions for tax purposes

Regulatory review: . General information only; it does not replace a project-specific legal, financial and technical assessment. Statutory figures, license categories and operating conditions must be confirmed against the law in force when applying.

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