Where to Incorporate Offshore for Shipping and Logistics

Choosing where to incorporate an offshore company for shipping and logistics isn’t just a tax exercise. It affects your access to finance, how quickly you can register and mortgage vessels, whether your P&I club is comfortable, how easy it is to open bank accounts, and your exposure to freight taxes, VAT/GST, and sanctions. I’ve watched owners save millions with the right structure—and I’ve also seen charters fall through because the counterparty wouldn’t accept a certain flag or jurisdiction. The “best” jurisdiction depends on what you do (owning vessels, operating, chartering, or logistics), where you trade, who finances you, and how much substance you can support.

First, separate shipping from logistics

Shipping and logistics often sit under one commercial umbrella, but legally and tax-wise they behave differently.

Pure vessel owning and international shipping profits: Many countries (via OECD Model Article 8 or domestic rules like U.S. IRC Section 883) tax profits from international shipping only in the place of effective management—or exempt them outright. This is why tonnage tax regimes (Malta, Cyprus, Netherlands, UK, etc.) and shipping incentives (Singapore, Hong Kong) are so prominent.

Logistics, freight forwarding, NVOCC, and warehousing: These are local services. VAT/GST, customs representation, agency licensing, and permanent establishment/substance issues matter more than flag or registry. Put bluntly: you can’t run a serious 3PL on a zero-substance offshore shell and expect to reclaim VAT or get trusted by customs.

Most global operators end up with a mix: ship-owning SPVs in shipping-focused jurisdictions; a management company where their team lives; and logistics/forwarding entities in trade hubs with VAT/customs capabilities.

What exactly are you incorporating for?

Clarity on purpose will eliminate half the noise. Typical use cases:

Single-vessel SPV: Owns one ship, charters it out (often bareboat or time charter), ring-fences liability, and supports bank mortgages.

Fleet holding company: Owns multiple SPVs; useful for financing, group treasury, and dividends.

Technical/crew management company: Holds DOC and MLC compliance; employs or subcontracts crew; bills management fees.

Commercial management/chartering desk: Fixes vessels; handles freight risk; may hold derivatives and FFA exposure.

NVOCC/freight forwarder: Needs licensing (e.g., FMC in the U.S.), surety bonds, agency networks, and strong banks.

3PL/4PL and e-commerce fulfillment: Warehousing, customs guarantees, VAT registration, deferred accounting schemes.

The right jurisdiction for one of these might be a poor fit for another. A Marshall Islands SPV is great for a tanker mortgage; it’s not how you run a bonded warehouse in Rotterdam.

The decision framework that actually works

Think in layers:

Tax and incentives

Are you eligible for a tonnage tax or shipping incentive? Can you actually meet the substance requirements?

Will you rely on U.S. Section 883 (exemption for international shipping income) or Article 8 treaty protection?

For logistics, how will VAT/GST and customs work? Can you defer or zero-rate?

Flag, registry, and finance

Will lenders accept your flag and registry? Top flags (Panama, Liberia, Marshall Islands, Malta, Cyprus) are widely recognized for mortgages.

Do you need fast registration and crew endorsements? Offshore registries can register within 24–72 hours with proper documents.

Substance and control

Where is management and control genuinely exercised? If high-tax countries view you as managed locally, they may tax you regardless of incorporation.

Economic Substance Regulations (ESR) in many offshore jurisdictions require meaningful activities and staff for “shipping” or “holding” activities.

Banking and payments

Banks de-risk aggressively. A tax-neutral company without real operations can struggle to open accounts. Combining an offshore SPV with an onshore management company and real cashflow helps enormously.

Geography and sanctions

Where do you trade? U.S./EU ports impose strict sanctions and AML expectations. Some flags and jurisdictions carry more compliance scrutiny than others.

Cost and speed

If you need a ship on the water this month, go with what you can stand up in days—not a jurisdiction that takes 10 weeks to bank.

I’ve listened to lenders say “no” to a deal purely due to registry unfamiliarity. I’ve also watched charterers insist on a change from a private registry to an EU one for optics. Those real-world constraints matter as much as tax.

Jurisdiction snapshots: where they fit and why

Marshall Islands (RMI)

Best for: Ship-owning SPVs, quick registrations, mainstream bankability, U.S.-style legal framework.

Why people choose it: Fast, responsive Maritime and Corporate Administrators; mortgages are lender-friendly; large share of global tonnage; recognized by P&I clubs.

Tax notes: Non-resident domestic corporations generally pay no local income tax on foreign-source income. ESR exists—if you claim to conduct “shipping business” from RMI, you’ll need substance. Most owners keep management elsewhere to align substance with the real team.

Practicalities: Incorporation often in 24–72 hours. Ship registration same day with provisional certs. Costs are mid-market. Good for fleets that trade globally, including the U.S.

Liberia

Best for: Similar to RMI; strong for mortgages; huge registry.

Why people choose it: One of the top three registries by tonnage, robust mortgage recording, competitive fees, responsive LISCR network.

Tax notes: Tax-neutral for non-Liberian-source income. ESR applies. Again, management often sits in Greece, Cyprus, Singapore, or elsewhere.

Practicalities: Smooth for lenders and P&I. Quick to set up and register vessels.

Panama

Best for: Bulk carriers and tankers; legacy fleets; cost-conscious owners.

Why people choose it: The world’s largest registry by gross tonnage with broad global recognition.

Tax notes: Territorial system—non-Panama-source income generally not taxed. Some counterparties perceive Panama as “old school,” but it’s still mainstream. Ensure KYC and compliance are tight.

Practicalities: Fast registration. Mortgage processes are established. Watch for banking challenges if the rest of your structure is too “offshore.”

Malta

Best for: EU flag credibility, tonnage tax regime, combining owning and management in one EU base.

Why people choose it: EU member; competitive tonnage tax approved by the European Commission; solid legal and maritime ecosystem.

Tax notes: Qualifying shipping activities fall into tonnage tax instead of corporate income tax. Proper substance is expected (directors, office, employees). VAT solutions for yacht leasing exist; not your focus if you’re cargo.

Practicalities: Good for EU lenders and charters who prefer an EU flag. Setup 2–4 weeks. Banking takes work but is feasible with real substance.

Cyprus

Best for: Ship owning, bareboat chartering, and ship management under a well-known EU tonnage tax regime.

Why people choose it: One of the most flexible regimes—covers owners, charterers, and managers. Many Greek-controlled fleets use Cyprus for management and commercial operations.

Tax notes: Tonnage tax replaces corporate tax on qualifying shipping income. Managers can qualify too. Zero withholding on most outbound payments; deep expertise pool.

Practicalities: Incorporation in 1–2 weeks. Banks want substance: real people, office lease, management agreements. Great home for commercial desks.

Madeira (Portugal) – MAR and the International Business Centre (MIBC)

Best for: EU flag through Portugal’s registry; low corporate tax (typically 5% within MIBC regime) if substance and caps are met.

Why people choose it: EU credibility with relatively low tax, crew and labor flexibility, competitive registry.

Tax notes: MIBC benefits are subject to EU-approved rules, caps tied to job creation or investment, and sunset timelines. Substance is not optional.

Practicalities: Solid for owners who want EU optics and cost-efficiency. Requires planning to meet MIBC conditions.

Isle of Man

Best for: Yachts and some commercial tonnage; UK Red Ensign Group benefits; UK VAT territory access (via Isle of Man).

Why people choose it: Highly regarded registry; UK law alignment; competent administrators.

Tax notes: 0% corporate tax for most activities (excluding certain sectors). Because IoM is in the UK VAT area, there are structured solutions for importation and leasing, particularly for yachts.

Practicalities: Strong for quality tonnage; credible with lenders.

Singapore

Best for: Global liner operators, ship managers, owners with Asia presence, and serious 3PL/logistics operations.

Why people choose it: World-class maritime cluster, top-tier banks, free-trade and bonded facilities, deep talent pool, and predictability.

Tax notes: Maritime Sector Incentive (MSI) offers reduced or even 0–10% tax on qualifying shipping income and related services for approved companies. GST is 9% in 2025; exports and transshipment can be zero-rated; free trade zones simplify customs.

Practicalities: Incorporation in days; banking in 2–4 weeks if your KYC is clean. Strong for substance. Also excellent for NVOCCs and freight forwarders with Asia networks.

Hong Kong

Best for: Ship leasing groups, chartering desks, and Asia-facing logistics with a territorial tax system.

Why people choose it: Simple tax; 16.5% profits tax only on Hong Kong–sourced profits; extensive tax arrangements for shipping and airlines; efficient port and services.

Tax notes: Concessions exist for ship leasing and ship management. International shipping income often falls outside HK tax if not Hong Kong–sourced. Document your sourcing position carefully.

Practicalities: Easy incorporation; solid banking if you have substance and clean ownership. Strong agency and broking presence.

United Arab Emirates (Dubai, Abu Dhabi free zones)

Best for: Middle East, Africa, and South Asia logistics hubs; regional headquarters; multimodal operations.

Why people choose it: World-class ports (JAFZA, Khalifa), no withholding taxes, ease of doing business, and Qualifying Free Zone Person regimes with 0% on qualifying income subject to rules. Corporate tax is 9% outside qualifying parameters.

Tax notes: Economic Substance Regulations enforced. Some free zones grant customs and VAT advantages; exports zero-rated. Getting QFZP status right is critical; assume you’ll need real people and premises.

Practicalities: Company setup 2–6 weeks; banking has improved but still requires credible substance and clean UBOs.

Netherlands

Best for: EU logistics headquarters, customs/VAT efficiency, and EU tonnage tax.

Why people choose it: Article 23 VAT deferment (import VAT postponed to VAT return), strong customs brokers, large distribution ecosystem, reliable banks.

Tax notes: Standard corporate tax applies, but tonnage tax can cover qualifying shipping income. Conditional withholding rules may affect payments to low-tax jurisdictions. Substance is scrutinized.

Practicalities: Outstanding for European warehousing and 3PL. Not “offshore,” but a workhorse for logistics.

Ireland

Best for: English-speaking EU base, tech-enabled logistics, and tonnage tax for qualifying shipping.

Why people choose it: 12.5% corporate tax (higher for large groups under OECD Pillar Two), EU market access, advanced supply chain sector.

Tax notes: Tonnage tax regime available; robust transfer pricing and substance expectations.

Practicalities: Banking is conservative; you’ll need a real operation.

UK

Best for: Shipping management, broking, and finance access; tonnage tax regime.

Why people choose it: Deep maritime services ecosystem in London; insurers, P&I clubs, and banks are local.

Tax notes: Corporate tax at 25%, but tonnage tax can apply to qualifying shipping income. Substance is a given.

Practicalities: Excellent for management entities; less used for “offshore” advantages.

Bahamas and Bermuda

Best for: Quality registries, certain finance or insurance-related structures alongside shipping.

Why people choose it: Well-run, stable, respected in the market; decent for yachts and commercial vessels.

Tax notes: Tax-neutral; ESR applies. Useful when matched with management in a substance-rich location.

Practicalities: Banking depends on your footprint and counterparties.

Cayman Islands

Best for: Yachts, structured finance SPVs, and mortgage-friendly corporate vehicles.

Why people choose it: Red Ensign Group registry; high governance standards; familiar to capital markets.

Tax notes: Tax-neutral; ESR applies.

Practicalities: Strong for finance; commercial shipping possible but less common than Malta/Cyprus/RMI/Liberia.

Labuan (Malaysia)

Best for: Asia-region owners seeking a midshore option with access to Malaysian infrastructure.

Why people choose it: Preferential tax regime under LBATA for Labuan entities (historically 3% of net audited profits or fixed amount—details evolve); proximity to ASEAN.

Tax notes: Treaty access is limited compared to Malaysia; substance and approved activities matter. Ensure the current LBATA position fits your model.

Practicalities: Useful niche; not universal. Bank carefully.

Flag, incorporation, and management: how they fit together

Place of incorporation: Where your company exists. Determines corporate law, reporting, and (sometimes) tax residence—though tax residence can move if management/control is elsewhere.

Flag state: Where the ship is registered. Determines safety, crewing standards, and where mortgages are recorded. It’s common to incorporate a Marshall Islands company and flag the vessel in Marshall Islands or another registry.

Place of effective management (POEM): Where strategic decisions are made. Many countries tax based on management/control. If your board meets in Athens and your CEO signs fixtures in Piraeus, Greece may claim taxing rights even if the company is incorporated in Liberia. Align form with reality.

Bareboat charter and dual registration can add flexibility. For example, you might own a vessel in RMI, bareboat charter it to a charterer who registers it under a local registry for cabotage purposes. Get legal advice: some flags limit dual registrations and mortgages.

Tax pillars that drive shipping choices

Tonnage tax vs. corporate tax: Under tonnage tax, you pay a fixed amount based on net tonnage, not profit. For a 50,000 GT vessel, annual tonnage tax might land in the tens of thousands of euros—often far less than corporate tax on profits. Malta, Cyprus, Netherlands, UK, and others have regimes with different eligibility and scope. Many cover owners and time charterers; some cover managers.

OECD Model Article 8: Many treaties assign taxing rights over international shipping to the state of effective management. This matters when calling in countries that otherwise impose freight taxes.

U.S. Section 883: Exempts income from international operations of ships if you’re organized in a “qualified foreign country” that offers equivalent exemptions and you meet public trading or ownership tests. If you trade to the U.S., make sure your structure fits 883. Liberia, Marshall Islands, Malta, Cyprus, and others can qualify—depending on ownership.

Withholding taxes on charters: Some countries impose withholding on freight paid to foreign shipowners. Treaties or 883 can mitigate this. Work with local agents to identify exposure—India and Brazil have rules that surprise newcomers.

VAT/GST for logistics: Freight often enjoys zero-rating, but warehousing, domestic trucking, and handling are vatable. EU logistics hubs rely on deferment schemes (Netherlands Article 23). In Singapore and UAE, free zones and zero-rating for exports/transshipments help cash flow.

Economic Substance is not optional

Most offshore centers now have ESR requiring “core income-generating activities” in the jurisdiction for relevant sectors, including shipping, holding, and headquarters activities. That typically means:

Qualified local directors who actually direct.

Local employees with appropriate skills.

Physical office and expenditure aligned with your revenue.

If you can’t justify that, move the function to a place where you can. Auditors and banks are already testing ESR in KYC; tax authorities are exchanging information under CRS and BEPS.

Banking: the real gatekeeper

A common mistake is to incorporate in a tax-neutral jurisdiction and then discover that no bank wants to open an account. A few practical tips:

Pair an offshore SPV with an onshore management company where you have substance and pay salaries.

Present full KYC: source of wealth, source of funds, charter contracts, management agreements, and P&I cover.

Choose banks used to shipping flows: Greece, Cyprus, Malta, Singapore, Hong Kong, and Northern Europe have relationship managers who understand bunker payments and hire-purchase structures.

Expect 2–8 weeks for onboarding if your structure is clean; longer if complex.

I’ve had clients open accounts in days when the bank officer already knew the P&I club and the manager’s reputation. That social credibility matters.

Common structures that work

A. Owner-operator with global trades, including the U.S.

Incorporate an SPV in Marshall Islands or Liberia.

Flag the vessel with the same registry.

Put commercial and technical management in Cyprus under the tonnage tax scheme, or in Singapore under MSI if Asia-focused.

Ensure U.S. 883 conditions are met—often via qualified ownership and registry.

Bank in Cyprus or Singapore with full KYC and management substance.

Why it works: Lender-friendly mortgage, tax-efficient management, and treaty/883 coverage for U.S. calls.

B. Time-charter-in fleet with Asia-centric routes

Holdco in Singapore; operating company under MSI (if eligible).

Use Singapore banks; settle hire from Singapore; hedge FFAs via a recognized broker.

For chartered tonnage, leave ownership SPVs with counterparties; focus on operational tax efficiency and customs where you call.

Maintain a small Hong Kong entity if you source fixtures or finance there.

Why it works: Operational hub with incentives and strong banking.

C. EU-focused ship management and brokerage

Incorporate in Cyprus or Malta under tonnage tax coverage for management activities (where eligible).

Build real substance: technical team, DPA, crewing desk.

Bank locally and in a second EU location for resilience.

Why it works: EU credibility, tonnage tax coverage for management income, acceptable flag mix.

D. Global 3PL and e-commerce fulfillment into the EU

Netherlands BV for warehousing and customs, with Article 23 VAT deferment.

Secondary entities in Germany/Belgium for last-mile coverage and labor flexibility.

Use AEO-certified customs brokers; run bonded warehouses to defer duties.

Keep a separate holding company in a stable jurisdiction if needed; but operational profits will sit in the EU.

Why it works: VAT cash-flow optimization, top-tier logistics ecosystem, and customer trust.

E. Middle East, Africa, South Asia logistics and feeder operations

UAE free zone company (JAFZA or similar) with real offices, QFZP compliance, and warehousing.

Use free zone customs benefits; zero-rate exports; manage regional tax exposure.

Consider a parallel Singapore company if you also serve East Asia.

Why it works: Powerful regional hub with modern infrastructure and tax-efficient free zone structures.

Special notes for NVOCCs and freight forwarders

U.S. FMC registration: A non-U.S. NVOCC must register and post a bond; many choose to incorporate in Hong Kong or Singapore and appoint a U.S. agent. If you move a lot of U.S.-bound cargo, consider a U.S. OTI subsidiary for commercial credibility.

Liability insurance: Ensure your jurisdiction supports enforceable limits and that your insurer is comfortable with your corporate setup.

VAT/GST: Forwarding invoices cross borders—map where service is consumed. In the EU, place-of-supply rules can zero-rate international freight; but local legs often attract VAT.

Electronic AWBs and eBLs: Choose jurisdictions and banks friendly to digital trade documentation.

Cost and timeline benchmarks

These vary by provider and complexity, but ballparks help planning:

Marshall Islands/Liberia SPV: Incorporation $2,000–$5,000; annual fees $1,000–$3,000; provisional ship registration within 24–72 hours; mortgage registration a few days once documents are ready.

Malta/Cyprus company: Incorporation €5,000–€10,000; annual maintenance €3,000–€8,000; tonnage tax per vessel often tens of thousands annually depending on size; bank onboarding 4–10 weeks with substance.

Singapore company: Incorporation S$2,000–S$5,000; annual maintenance S$2,000–S$6,000; incentives require applications and audits; bank accounts 2–4 weeks; customs/FTZ permits additional.

Netherlands BV: Incorporation €3,000–€7,000; Article 23 application several weeks; warehouse licensing 1–3 months; banking 4–12 weeks.

UAE free zone: Company setup $5,000–$15,000; office lease required; bank onboarding highly variable (3–10 weeks).

Vessel registration fees, radio licenses, and safety certificates are additional and depend on flag and vessel particulars.

Compliance and risk: where deals stumble

Sanctions and AML: Screen ownership, counterparties, and ports. Some registries are quicker than others to act on sanction updates; your flag choice can affect operational risk.

Cabotage: Don’t assume your offshore-flagged vessel can move domestic cargoes. Plan for waivers or local partners.

MLC and crew tax/social security: Ensure your corporate structure aligns with crew contracts and social security contributions. Some EU flags offer flexible solutions via agreements on seafarers.

Transfer pricing: If management fees move profits to a low-tax location, expect audits. Benchmark your fees and document functions, assets, and risks.

Place of effective management: Boards that never meet, directors who don’t direct, and “rubber-stamped” minutes are red flags. Authorities notice.

Section 883 ownership test: Complex private owner structures sometimes fail the qualified shareholder or public trading test. Fix it before calling the U.S.

How to pick a jurisdiction: a step-by-step path

Map your activities

Are you owning ships, chartering, managing, or running logistics—or a combination? Write down revenue streams and where services are performed.

Identify tax regimes and flags that fit

For owners/charterers: shortlist Malta, Cyprus, RMI, Liberia, and Singapore. For logistics: Netherlands, Singapore, UAE, Ireland.

Check U.S. 883 exposure and treaty protection for your routes.

Decide where real management sits

Put the management company where your decision-makers actually live. If that’s Piraeus or Limassol, lean into it. Substance reduces audit risk and helps banking.

Pick a lender-friendly registry

Ask your bank or broker which flags they prefer. Don’t guess—your mortgage registration needs to be smooth.

Stress-test banking

Before incorporating, talk to banks. If you can’t open an account in 30–60 days, consider alternative jurisdictions or adjust the structure.

Build a compliance calendar

Include tonnage tax returns, ESR filings, MLC audits, VAT filings, and sanctions screenings. Assign owners and deadlines.

Pilot with one asset or lane

Set up one SPV or one logistics entity and run it for a month or two. Fix bottlenecks, then scale.

Practical examples

A mid-sized tanker owner added a Cyprus management company under tonnage tax to replace a “letterbox” setup. Annual tax dropped materially versus corporate tax on profits, the bank increased the facility after seeing real staff on the ground, and the P&I renewed without extra conditions.

A fast-growing 3PL moved its European distribution from a non-VAT entity to a Netherlands BV with Article 23. Import VAT cash-flow savings freed mid-seven figures annually, and customer onboarding sped up because customs processes were standard.

An Asia-based operator obtained Singapore MSI status for a 10-year award covering qualifying shipping income. Banking lines improved because the government endorsement signaled substance and scale.

Jurisdiction quick comparisons by profile

Cost-focused single-vessel owner with mainstream financing: Marshall Islands or Liberia SPV; flag same; management in Cyprus or Greece; bank in Cyprus or Greece; ensure 883.

EU-oriented fleet with reputation sensitivity: Malta or Cyprus owning/flagging; EU tonnage tax; banking in EU; mix of RMI/Lib/MT flags as needed.

Asia-focused liner or feeder: Singapore HQ with MSI; operating companies for each lane; possibly Hong Kong for leasing or broking; regional subsidiaries for local taxes.

Premium yacht or high-end asset: Cayman or Isle of Man registry; management in IoM/UK/Malta; VAT planning if used in EU waters.

Middle East/Africa logistics: UAE free zone entity with warehousing; optional RMI/Liberia SPVs for chartered vessels; banks in UAE and Singapore.

Numbers and data points worth knowing

Registry concentration: The top three flags—Panama, Liberia, and Marshall Islands—collectively represent roughly 40–50% of global gross tonnage. Lenders know their mortgage processes cold.

Tonnage tax economics: For a Handymax to Panamax vessel, annual tonnage tax under EU regimes can be a fraction of what traditional corporate tax would be during a strong market. Even in weak markets, predictability helps with cash flow and covenants.

Banking timelines: Clean, substance-backed structures open accounts in 2–8 weeks; pure offshore shells can take months or fail outright.

VAT cash flow: Moving EU imports to the Netherlands with Article 23 typically eliminates upfront import VAT, which otherwise ties up 20%+ of cargo value until reclaimed.

Mistakes to avoid

Paper substance: Hiring a nominal director who never attends meetings or signing all fixtures from a different country invites POEM challenges and ESR failures.

Flag misalignment: Choosing a registry that your lender dislikes or that struggles with your vessel type. Always check ship type experience (LNG, offshore, ro-ros, etc.).

U.S. exposure without 883: Calling U.S. ports under a structure that fails 883 tests can result in unexpected U.S. tax. Fix ownership or registry before you sail.

Using a tax haven for logistics: You won’t get VAT numbers, customs guarantees, or trusted relationships. Put logistics where customs and VAT administration exist.

Banking afterthought: Incorporating first and hoping a bank will say yes later is risky. Reverse the process: pre-clear your KYC path with a bank or two.

Ignoring sanctions: Registries, insurers, and banks will walk away if your counterparty map is weak. Build a sanctions screening workflow and document it.

What I recommend by scenario and risk appetite

Conservative and bank-led: RMI/Liberia SPVs + EU or Singapore management + EU, Singapore, or Greece banking. Reliable flags, clear management, and scalable processes.

EU optics with tax efficiency: Malta or Cyprus for both owning and management under tonnage tax, plus a Netherlands logistics entity if you handle EU imports.

Asia growth platform: Singapore HQ with MSI; partner with Hong Kong for leasing or chartering desks; substance in both locations; banks across SG/HK.

Regional logistics dominance: UAE free zone for MEASA with real offices; pair with Singapore for Asia procurement and treasury; Netherlands for EU distribution.

Implementation checklist

Jurisdiction shortlists and flag acceptability from your bank and P&I club

Corporate structure chart with real management and ESR mapping

Tax memo covering tonnage tax, 883, Article 8, and VAT/customs

Banking pre-approval with draft KYC pack (UBO docs, source of wealth, charters, P&I, management agreements)

Compliance calendar (ESR filings, tonnage returns, VAT, audits)

Contract templates aligned with structure (charterparties, management agreements, pooled arrangements)

Sanctions and AML procedures with named owners

Final thoughts

You don’t need the “perfect” jurisdiction—you need one that your lenders, charterers, insurers, and tax advisors all accept, that you can stand up quickly, and that you can defend under audit. For most owners, that points to a blend: offshore SPVs in a lender-friendly registry, a real management company where your people sit, and operational entities in logistics hubs where customs and VAT actually work. If you can explain your structure in two minutes to a skeptical banker and they nod, you’re on the right path.