The Nevis Multiform Foundation with an LLC Beneath It: A Two-Layer Structure That Changes Form When Your Life Changes Country

Status as of 25 October 2026: based on the Nevis Multiform Foundations Ordinance, Cap. 7.08 (revised edition to 31 December 2017), the Nevis Limited Liability Company Ordinance, Cap. 7.04(N) (revised edition to 31 December 2020) and its Amendment Ordinance No. 3 of 2023, the Nevis LLC Amendment Ordinance 2018, the published information and fee schedules of the Nevis Financial Services Regulation and Supervision Department, the German Fiscal Code (§§ 8, 9 AO), the German Income Tax Act (§ 1 EStG), the German Foreign Tax Act (§§ 2, 6, 7 to 13 and 15 AStG), the German Inheritance and Gift Tax Act (§ 7 ErbStG), the Romanian Fiscal Code and the Cyprus Income Tax Law. Official fees are those published by the regulator as of October 2026. We will update this guide when the law changes.

Updated 25 October 2026: added the comparison with a Wyoming LLC and the combined Wyoming and Nevis design.

Families with real money rarely own their assets in their own name. They own a structure. The structure owns a company. The company owns the portfolio, the shares, the property, the rights. When a creditor, an ex-partner or a government looks for "their money", it finds layers, each with its own rules, its own law and its own purpose.

For a long time this was the privilege of people with a family office. Until now. A well-built two-layer structure is no longer a luxury for the very wealthy: it is a planning decision that a founder, an investor or a family with a serious balance sheet can make deliberately. Through Bogdan and ENCC, you can sit at the same table: we coordinate the design, and licensed partners in Nevis and in your home country set it up in their own name.

This guide explains the structure we are asked about most often in this category: a Nevis Multiform Foundation at the top and a Nevis Limited Liability Company beneath it. It is written for people who live in more than one country over a lifetime, because that is where this structure is strongest. The Multiform can change its legal form when your life changes country.

The structure in one picture

Two layers, two jobs. Think of it as a house with a roof and a foundation stone, except that the order is reversed.

The foundation is the owner of last resort. The LLC is the vehicle that meets the world. If something goes wrong at the level of the assets, a lawsuit, a failed investment, a contract dispute, it is the LLC that is exposed, not the foundation and not the family. If something goes wrong at the level of a person, a creditor of a family member, a divorce, a dispute between heirs, the foundation's rules and the LLC's charging order rules stand between that person's problem and the assets.

Why a Multiform, and not an ordinary foundation

Most entities are frozen in the form they were born in. The Multiform is not. A company stays a company, a trust stays a trust, a foundation stays a foundation. If your life changes and the form no longer fits, the usual answer is to dissolve one entity and transfer everything to another. Every transfer is a moment of risk: tax, legal challenge, bank questions.

Nevis took a different approach. The Multiform Foundations Ordinance allows one registered entity to be declared as a foundation, a trust, a company or a partnership, and to change from one of these forms to another by amending its constitution. The Nevis regulator describes the Ordinance as "very unique and cutting-edge legislation". We use the regulator's words because they are the regulator's: in the comparative work behind our foundations comparison of Liechtenstein, Nevis and Panama, we did not find another law that lets a single registered entity switch between these four forms in the same way.

What the law says about changing form

• The first form is declared at registration. Section 10 of the Ordinance requires the multiform foundation to state its multiform when it is established.
• The form can be changed. The foundation changes its stated multiform by amending its constitution. The documents are delivered to the Registrar within 14 days of the resolution, and the change takes effect when the Registrar issues an amended certificate.
• The entity continues. Section 10(5) provides that the change does not affect the foundation's existence, its rights and obligations, or any legal proceedings. It is the same entity in a new form, not a new entity.
• One form at a time. Section 10(6): the foundation has one stated multiform at any time.
• The Registrar can say no. Section 10(7) allows the Registrar to refuse a change.
• The forms. Section 10(9): as a trust, the by-laws operate as the trust deed and the Trusts Ordinance applies; as a company, the corporate rules apply, and if the foundation is stated to be a limited liability company the LLC Ordinance applies, with the members treated as absolute beneficiaries; it can also be stated as a partnership. Section 10(10) allows the Minister to add forms.

The regulator's own summary adds that the Ordinance also allows continuance and conversion: a trust from another jurisdiction, for example Jersey, can become a Nevis Multiform, and a Nevis company can convert into one. Our detailed guide to the Nevis Multiform Foundation walks through every provision.

The point of it all: a form for each country you live in

Your home country decides how it sees your structure. Tax authorities and courts classify a foreign entity by comparing it with entities they know. A civil-law country understands a foundation; a common-law country understands a trust; almost every country understands a company. A structure that looks familiar is easier to explain, to bank and to report.

The Multiform lets the structure follow you. The cards below are not tax advice. They describe the question your advisers will ask in each situation and the kind of answer the Multiform makes possible.

A change of form is a legal event, and possibly a tax event. The Nevis law preserves the entity's continuity. Your home tax law may not. In Germany, for example, moving from a foundation form to a company form can switch the applicable regime from the family-foundation rules to the controlled foreign company rules, and may be treated as a disposal or a new transfer. The flexibility is real, and it is valuable only when each step is tested at home before it is taken.

The LLC beneath: why the foundation should not hold assets directly

A foundation is good at holding. It is not built to trade. You could put an investment account or a shareholding directly into the foundation. Many families prefer to keep the foundation clean, with one asset, the LLC, and let the LLC do everything else. There are four reasons.

Liability stays below. If the LLC signs a contract that goes wrong, the LLC is liable. The foundation, as member, is not liable for the LLC's debts beyond what it put in.

Several LLCs, several risks. One LLC for the portfolio, one for a property, one for intellectual property. A problem in one does not reach the others.

Banks and brokers know LLCs. An LLC with an operating agreement, a manager and a clear purpose is a familiar client. A foundation in trust form is a different compliance file.

The member's interest is protected by its own statute. The Nevis LLC Ordinance has charging order rules that are among the most protective we have reviewed, layered on top of the foundation's own rules.

What the Nevis LLC Ordinance provides

• Separate legal entity. The LLC is a legal person distinct from its members. It can be formed for any lawful purpose.
• One member is enough. Section 55(4) allows an LLC to operate with a single member who holds all the interests. A foundation can be that member.
• Flexible management. The LLC can be managed by its members or by managers, and the Ordinance lets the management be organised in the way the operating agreement provides.
• Simple formation. The LLC is formed by filing Articles of Organization with the Registrar of Companies. A written operating agreement, setting out who manages, who decides and how distributions are made, is the document that makes the structure work in practice.
• Mobility. The Ordinance provides for transfer of domicile into and out of Nevis, including an emergency transfer.
• Records. The 2023 amendment added detailed record-keeping duties: registers of members and managers, records kept for six years after dissolution, with penalties of up to 10,000 dollars for breach. It also introduced electronic filing on the Registrar's portal.

Charging order: what a creditor of the member can and cannot do

Section 60 is the core. If a creditor of the member obtains a judgment, the charging order is the sole remedy against the member's interest in the LLC, whether the LLC has one member or many. In plain language: the creditor can ask the court for the right to receive distributions that would otherwise go to that member, if and when they are made. That is all.

• No seizure, no forced sale. The creditor cannot foreclose on the interest, attach it or seize LLC property.
• No control. The creditor gets no right to vote, manage or demand distributions, and cannot interfere with the LLC's management.
• No injunctions against the LLC because of a member's debt.
• Time-limited. A charging order is not renewable and expires after three years.
• No fines or punitive damages through the charging order.
• Proof and time limits on fraud claims. Under section 61, a creditor claiming that a transfer to the LLC was fraudulent must prove it beyond reasonable doubt, and must act within short windows: two years from the cause of action, or one year after the transfer, depending on the case.
• Security for costs. Under section 62, a creditor who wants to collect on a judgment against the member or the LLC must first post a bond in an amount fixed by the High Court.

What this means in the structure. A creditor of yours personally meets the foundation first. A creditor of the foundation, which in a well-run structure should be nobody, meets the LLC's charging order rule. A creditor of the LLC meets the LLC's own assets, not the family's. Each layer has a different defence.

The foundation's own protection

The Multiform Ordinance has its own wall. Under section 83, a creditor suing the foundation must first deposit a bond of 50,000 dollars from a financial institution in Nevis, and section 2 defines dollars as US dollars. Under section 108, a creditor alleging a fraudulent transfer must prove intent to defraud beyond reasonable doubt, and a transfer made more than one year after the creditor's cause of action accrued is not fraudulent against that creditor. A creditor whose claim arose earlier has six months from the transfer. Under section 110, foreign judgments against the foundation are not enforced in Nevis. Under section 46, foreign forced-heirship rules do not invalidate the foundation or transfers to it.

What these rules do not do. They bind Nevis courts. A court in Germany, Romania, Cyprus or the United States can still act against you personally: order you to disclose, to repatriate, or treat rights you kept as your own property. The structure is strongest when you have given up control in a genuine way, transferred early, and have nothing to hide from your own tax authority. Protection rewards planning, never concealment.

Why this pairing works: the strengths in plain words

Put simply, the foundation decides who the wealth is for, and the LLC decides how it is held. Both sit under one legal system, with one registered agent and one set of courts. That simplicity is a strength in itself: fewer laws that can contradict each other, fewer advisers who must agree.

• A creditor waits, and the clock runs against them. Against a member's interest, the only remedy is a charging order (Nevis LLC Ordinance, s.60). It is not renewable and it expires three years after it is made (s.60(15)).
• Fines and punitive damages do not pass through. They are excluded from what a charging order can collect (s.60(3)).
• A foreign judgment does not open the door. A foreign judgment against a member's interest is not enforced by the Nevis High Court (s.60(7)), and no court order giving a creditor control over the LLC or its assets is enforceable (s.60(12)). Injunctions against the LLC for a member's debt are not allowed (s.60(14)).
• Fraud must be proven to the criminal standard. A creditor attacking a transfer must prove, beyond reasonable doubt, an intent to defraud and insolvency, within short time limits (s.61).
• Collecting costs money up front. Before taking action to collect on a judgment, a creditor must first post a bond, in an amount set by the High Court (s.62). You will often read a fixed figure online; the consolidated text we read does not set one.

What it does not do. It does not cut tax at home and it does not hide anything from your tax office. Nevis takes part in the OECD Common Reporting Standard, so a bank account of the structure outside the US is normally reported to the country where the founder or beneficiaries live. And since 2019, newly formed Nevis LLCs no longer enjoy the old automatic tax exemption.

Nevis LLC or Wyoming LLC under the Multiform?

The question we hear most: "Why not a Wyoming LLC? It is cheaper and American." It is a fair question. Wyoming is a serious jurisdiction, and its law also makes the charging order the exclusive remedy, expressly including a single-member LLC (W.S. 17-29-503(g)). The difference is in the details, and in where the assets sit.

	Nevis LLC	Wyoming LLC
Charging order is the only remedy	Yes (s.60)	Yes, including a sole member (17-29-503(g))
Charging order expires	After 3 years, not renewable	No expiry in the statute
Bond before a creditor enforces	Yes, set by the High Court	None in the statute
Fines and punitive damages	Excluded	No exclusion in the statute
Where a creditor must go	Nevis courts	US courts
US filings for a foreign owner	Normally none, if there is no US activity; US-source income still meets US withholding	Form 5472 with a pro forma Form 1120 for each year with reportable transactions (in practice every year), EIN required; USD 25,000 penalty per late or incomplete form, plus USD 25,000 for each further 30 days if not filed within 90 days of an IRS notice
Beneficial ownership report to FinCEN	Not applicable	None: US-formed entities are exempt (interim rule March 2025, final rule August 2026)
Banking	Harder; often Swiss, Liechtenstein or Caribbean banks	Easier; US banks, fintechs and payment processors
Automatic exchange of account data	Nevis is in CRS	The US is not in CRS (it uses FATCA)
EU list (October 2026)	Not listed	Not listed

In one sentence: Nevis is stronger at keeping wealth safe; Wyoming is better at doing business. A Wyoming LLC with US staff, a US office or other regular activity in the US can carry on a US trade or business, and its profits can then be taxed in the US as effectively connected income. A passive Nevis holding normally does not, although US dividends and similar US-source income paid to it are still subject to US withholding tax.

A warning about reporting. The fact that the US does not exchange data under CRS is not a tax benefit. If you live in the EU, you must declare your income and your structure at home in any case. We never design a structure around a reporting gap, and neither should you.

Paying from a Cyprus company? Since 1 January 2026, Cyprus Law 47(I)/2025 applies defensive measures to certain payments, such as interest and royalties, from a Cyprus company to related companies resident or registered in a "low-tax jurisdiction": a non-EU jurisdiction whose corporate tax rate is below half of the Cyprus rate. Whether a payment to a Nevis entity is caught depends on how this test applies to St Kitts and Nevis and to the entity concerned. Your Cyprus tax adviser must check this before any payment flows.

The combined route: a Wyoming company that works, a Nevis company that keeps

Many people do not have to choose. A common design has three parts:

1. The Multiform Foundation at the top. It owns everything and sets the family rules.
2. A Wyoming LLC that runs the business. It signs with customers, takes payments, uses a US bank. It holds only working capital.
3. A Nevis LLC that holds the reserve. Profits that are no longer needed in the business move up, are taxed and declared as your home country requires, and are kept in the Nevis LLC, away from the trading risk.

The logic is simple: the company exposed to customers and contracts holds little; the company that holds a lot is exposed to nothing. If the business is sued, the claim meets a Wyoming LLC with a thin balance sheet, not the family reserve.

The price of this design: two LLCs to maintain, the yearly US Form 5472 for the Wyoming company, real minutes and real transfers between the entities, and a home-country analysis of each flow. Money moved up after a claim has arisen can be attacked as a fraudulent transfer in either country. The structure works when it is built early, while nothing is wrong.

Official fees, as published by the regulator

These are government fees only, as of October 2026. Registered agent, legal and tax adviser fees come on top and depend on the partner and the work. We do not publish provider prices.

Nevis tax: the easy part, if it is done correctly

For the foundation. Section 93 of the Multiform Ordinance exempts a multiform foundation that transacts business exclusively with persons not resident in Nevis from Nevis income tax and other Nevis taxes, within the terms of the section. It may elect Nevis tax residence and be taxed at not more than one percent (section 93(3)), and there is no Nevis estate, inheritance or gift tax on it (section 93(4)). The regulator's 2018 announcement named the company and LLC ordinances, not the Multiform Ordinance; we have the current status of section 93 confirmed by the registered agent before formation.

For the LLC. The rules changed. Under the 2018 amendment, the old blanket tax exemption for Nevis LLCs ended for LLCs formed after 31 December 2018, and grandfathering for older LLCs ended on 30 June 2021, according to the regulator's announcement. Today the practical position, as commonly applied, is that an LLC which is not managed and controlled in St Kitts and Nevis and has no permanent establishment there falls outside Nevis corporate income tax, while an LLC that is tax resident there is taxed under the general rules. We have each LLC's position confirmed by the Nevis registered agent and tax adviser before formation.

Nevis tax is rarely the real question. Your home country's tax is.

Home-country tax: where structures succeed or fail

Your home country classifies each layer by its own rules, and it does not care what Nevis calls it.

Germany: more than two ways to remain taxable

Before any foreign structure, a German resident must know whether they are still German resident. There are more routes into German taxation than the "six months" most people know.

• A dwelling, § 8 AO. You have a Wohnsitz where you hold a dwelling in circumstances suggesting you will keep and use it. No minimum days apply. A flat you kept, a room at your parents' or a key to a friend's apartment that you use on visits can be enough, even for a handful of nights.
• Habitual abode, § 9 AO. A continuous stay of more than six months always counts; short interruptions do not break it.
• State employees abroad, § 1(2) EStG. German nationals employed by a German public body and paid from German public funds, such as diplomats, remain unlimited taxable.
• On application, § 1(3) EStG. Non-residents with mainly German income can choose unlimited liability.
• Extended limited liability, § 2 AStG. German nationals who move to a low-tax country while keeping substantial German economic interests can stay taxable on a wider range of German income for ten years after the move.
• Exit tax, § 6 AStG. When unlimited liability ends, shareholdings of at least 1% can be taxed as if sold. The same rule also applies to a gratuitous transfer of such shares to a person who is not unlimited taxable in Germany, which can include a foreign foundation or LLC.

Then come the structure rules.

• Foundation and trust forms, § 15 AStG. Income of a foreign family foundation is attributed to a German-resident founder, or otherwise to German-resident beneficiaries. The EU and EEA exception in § 15(6) does not apply to Nevis.
• Company forms and the LLC, §§ 7 to 13 AStG. Germany compares the foreign entity with German types. An LLC may be treated as a corporation or as transparent depending on its features. If it is treated as a controlled foreign company with passive, low-taxed income (taxed at less than 15%), that income can be attributed to the German shareholder.
• Gift tax on the endowment, § 7(1) no. 8 ErbStG. Transferring assets to a foundation is a taxable gift. The family foundation class rule in § 15(2) ErbStG applies only to foundations set up in Germany, so a transfer to a Nevis foundation is normally taxed in tax class III, the least favourable class.
• Change of form. Moving between foundation and company forms can move you between § 15 AStG and §§ 7 to 13 AStG, and can be treated as a disposal or a new transfer. A German tax opinion comes first.

Our guide to German tax residency rules explains the residence tests, and exit tax and the Cyprus year end explains § 6 AStG in practice.

Romania

Romanian law has no private family foundation; foundations under Government Ordinance 26/2000 serve general or community purposes. Dividends paid to Romanian resident individuals are taxed at 16% for distributions from 2026. A company form or an LLC treated as a company is likely to be read through these rules. There is no specific regime for distributions from a foreign private foundation or trust, and practice is unsettled, which is a reason to obtain a Romanian tax opinion before any transfer. Romanian CFC rules apply to Romanian companies that control low-taxed foreign entities.

Cyprus

For a Cyprus tax resident who is not domiciled in Cyprus, dividends carry no SDC under the Non-Dom rules and are outside personal income tax, with GESY at 2.65% on a capped base. How a Cyprus authority characterises a distribution from a foreign foundation or trust form is a separate question, to be confirmed by a Cyprus tax adviser. If the LLC or the foundation is in practice managed from Cyprus, it can become Cyprus tax resident itself; our guide on the place of effective management explains the test.

United States

The US classifies foreign entities under the entity classification rules (the check-the-box regulations, Treas. Reg. § 301.7701-3). An LLC may elect its classification; a foundation in trust form is likely to be tested under the US trust rules, with heavy reporting for US persons. US persons need US advice before anything else.

Transparency: private, not secret

St Kitts and Nevis participates in the Common Reporting Standard. Accounts held by the LLC or the foundation are reported to the tax authorities of the controlling persons' countries of residence: for a foundation or trust form, typically the founder, board members, protector or supervisory board and beneficiaries; for a company form, the controlling persons. Registered agents must hold beneficial ownership information and make it available to competent authorities. Economic substance rules apply to certain activities and should be checked with the registered agent.

The structure protects you from the public and from opportunistic creditors. It does not hide you from your own tax authority, and it should not try to. Do it right and nobody has a reason to question it.

When this structure is the wrong tool

We say so before you spend money. The two-layer Nevis structure is usually the wrong tool if:

• the assets are small relative to the running costs of two entities, a registered agent and annual advice in two countries;
• you need to transfer assets after a claim is already visible: a late transfer invites a court at home to look through the structure;
• you want to keep full personal control: the more you keep, the less the structure protects and the more your home tax law treats the assets as yours;
• you are a US person without a US-specific plan;
• the main goal is a lower tax rate: the structure is about ownership, succession and protection; tax is decided at home.

How we build it, step by step

1. Your written brief. Assets, countries of residence now and likely later, family, heirs, existing companies, any known disputes.
2. Home-country tax opinion first. For each country where you or a beneficiary live, a licensed adviser tests the foundation form, the LLC and the planned changes of form.
3. Design. First form of the foundation, purpose, beneficiaries, management board, secretary, supervisory board if any, founder rights kept and given up; number and purpose of LLCs.
4. Registered agent onboarding in Nevis. Due diligence on you and the source of the assets.
5. Establishment of the foundation. Memorandum of establishment, constitution and by-laws, certificate from the Registrar.
6. Formation of the LLC. Articles of Organization, operating agreement, manager appointment, foundation admitted as sole member.
7. Banking and custody. Accounts for the LLC with institutions that accept the structure.
8. Endowment and transfers. Only after the home-country tax steps (gift tax, exit tax, reporting) are clear and documented.
9. Annual life. Returns, renewals, records, CRS, board decisions taken where the board actually sits.
10. Review at every move. When you or a beneficiary change country, the form is reviewed before the move, not after.

Common mistakes

• Transferring first, asking about tax later. In Germany the transfer itself can trigger gift tax and exit tax.
• Changing form without a home-country opinion. Nevis preserves continuity; your home country may see a disposal.
• Founder keeps every right. Protection and tax treatment both suffer.
• Running the LLC from your kitchen table at home. The LLC can become tax resident where it is really managed.
• Treating "private" as "secret". CRS and beneficial ownership rules apply.
• Funding after a claim appears. Short time windows help early planners, not late ones.

Illustrations (not clients)

These examples describe typical situations. They are illustrations, not real clients, and the tax outcome in each case depends on advice in the countries involved.

The German founder planning a move. A founder in Bavaria holds a valuable GmbH and a securities portfolio and expects to move to Cyprus within two years. Her German adviser warns that transferring the GmbH shares to a foreign foundation now could trigger § 6 AStG as a gratuitous transfer, plus gift tax. The plan: establish the foundation and a Nevis LLC for the portfolio only, in foundation form, with a German opinion on § 15 AStG; leave the GmbH where it is until the exit tax position on her move is clear.

The Romanian family with heirs in three countries. Parents in Romania, one child in London, one in Vienna. The family values a single vehicle that can be read as a trust in England and as a foundation in Austria. A Multiform with an LLC holding the investment account lets them choose the form at the moment that matters, with each change tested with advisers in the countries concerned.

The investor who becomes an operator. An investor living in Cyprus starts acquiring small operating companies. Banks and sellers are more comfortable with a company at the top. Rather than dissolving the foundation, the advisers consider changing its stated multiform to a company, after a Cyprus and Nevis review of the consequences.

The circle

The people who build this structure share a way of thinking. They treat wealth as private property, not as a temporary permission. They design their residence instead of inheriting it. They keep more than one exit, and they plan for their children's lives in countries they have not chosen yet. They prefer a structure they can explain to their own tax authority over one they have to hide.

ENCC is where they bring the design question. We coordinate; licensed partners in Nevis and in each home country do the legal, banking and tax work in their own name. A Plan B with a backup is not paranoia. It is prudence.

FAQ

Can the Multiform Foundation be the sole member of a Nevis LLC?

Yes. The LLC Ordinance allows an LLC with a single member holding all interests, and a legal person can be a member. The foundation in that role is the typical design.

Can the foundation really change from a foundation to a trust or a company?

Yes, under section 10 of the Ordinance, by amending its constitution and filing within 14 days. The change takes effect when the Registrar issues an amended certificate, the entity continues, and the Registrar may refuse.

Does a change of form trigger tax?

Not in Nevis as such. At home it can. In Germany, moving between foundation and company forms can change the applicable regime and may be treated as a disposal or new transfer. Always get a home-country opinion first.

What can a creditor of mine do against the LLC?

If the creditor is your personal creditor and you hold the LLC through the foundation, they face the foundation's rules first. A creditor of an LLC member is limited to a charging order, which gives no control, cannot force distributions and expires after three years.

Does this structure make tax disappear?

No structure is free of tax by itself. The foundation can be exempt from Nevis tax under section 93 and the LLC can be outside Nevis tax if managed and controlled outside St Kitts and Nevis, but your home country taxes according to its own rules.

Will my bank and my tax authority know?

Yes. CRS reporting and beneficial ownership rules apply. The structure gives privacy from the public, not secrecy from authorities.

What are the official fees?

As of October 2026, the regulator publishes USD 300 for the foundation's certificate of establishment and USD 300 for its annual return, USD 300 for the LLC's Articles of Organization and USD 300 for its annual renewal. Professional fees come on top.

How is this different from your earlier Nevis Multiform guide?

That guide explains the Multiform Ordinance in depth. This one explains the two-layer structure with an LLC beneath, and how to use the change of form across countries.

Do I have to move to use it?

No. It is often set up while you still live at home. The home-country tax steps then become even more important.

Next steps

Start with the comparison of private foundations in Liechtenstein, Nevis and Panama, then read the deep dive on the Nevis Multiform Foundation. For trusts, see Cook Islands trust or Nevis DAPT; for the wider picture, asset protection and privacy. If an operating company in Cyprus sits under the LLC, today's companion guide on audit or review for a Cyprus Ltd explains its accounts. All guides are on the English blog.

Sources

• Nevis Multiform Foundations Ordinance, Cap. 7.08 (revised to 31 December 2017), Nevis Financial Services Regulation and Supervision Department: https://www.nevisfsrc.com/wp-content/uploads/2023/06/Ch-07.08N-Multi-form-Foundations-Ord.pdf
• Nevis Limited Liability Company Ordinance, Cap. 7.04(N) (revised to 31 December 2020): https://www.nevisfsrc.com/wp-content/uploads/2023/06/Ch-07.04-N-Nevis-Limited-Liability-Company-Ordinance.pdf
• Nevis Limited Liability Company (Amendment) Ordinance No. 3 of 2023: https://www.nevisfsrc.com/wp-content/uploads/2023/10/NLLCO-Amendment-Ordinance-No.-3-of-2023.pdf
• Nevis Limited Liability Company (Amendment) Ordinance 2018: https://www.nevisfsrc.com/wp-content/uploads/2019/01/Nevis-Limited-Liability-Company-Amendment-Ordinance-2018.pdf
• Nevis regulator, foundations (information and fees): https://www.nevisfsrc.com/services/foundations/
• Nevis regulator, limited liability companies (information and fees): https://www.nevisfsrc.com/services/llcs/
• Nevis regulator, announcement on amendments to offshore legislation (28 December 2018): https://www.nevisfsrc.com/nia-amends-legislation-governing-nevis-offshore-financial-services-sector-to-satisfy-eu-demand/
• German Fiscal Code, § 8 AO: https://www.gesetze-im-internet.de/ao_1977/__8.html
• German Fiscal Code, § 9 AO: https://www.gesetze-im-internet.de/ao_1977/__9.html
• German Income Tax Act, § 1 EStG: https://www.gesetze-im-internet.de/estg/__1.html
• German Foreign Tax Act, § 2 AStG: https://www.gesetze-im-internet.de/astg/__2.html
• German Foreign Tax Act, § 6 AStG: https://www.gesetze-im-internet.de/astg/__6.html
• German Foreign Tax Act, § 7 AStG: https://www.gesetze-im-internet.de/astg/__7.html
• German Foreign Tax Act, § 15 AStG: https://www.gesetze-im-internet.de/astg/__15.html
• German Inheritance and Gift Tax Act, § 7 ErbStG: https://www.gesetze-im-internet.de/erbstg_1974/__7.html
• Romanian Fiscal Code, Law 227/2015 (ANAF): https://static.anaf.ro/static/10/Anaf/legislatie/Cod_fiscal_norme_2023.htm
• US Treasury Regulations, § 301.7701-3 (eCFR): https://www.ecfr.gov/current/title-26/section-301.7701-3
• OECD, Common Reporting Standard: https://www.oecd.org/tax/automatic-exchange/common-reporting-standard/
• Wyoming Limited Liability Company Act, W.S. 17-29 (Secretary of State): https://sos.wyo.gov/Forms/WyoBiz/Wyoming_Limited_Liability_Company_Act_and_Close_LLC_Supplement.pdf
• FinCEN, Beneficial Ownership Information: https://www.fincen.gov/boi
• Federal Register, BOI reporting requirement revision (14 August 2026), 2026-16576: https://www.federalregister.gov/documents/2026/08/14/2026-16576/beneficial-ownership-information-reporting-requirement-revision
• Council of the EU, EU list of non-cooperative jurisdictions: https://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/
• Cyprus Law 47(I)/2025: https://www.cylaw.org/nomoi/arith/2025_1_047.pdf

Verified on 25 October 2026.

Cover photo: ferry pier at Charlestown, Nevis. Photo: Dr. Thomas Liptak, Wikimedia Commons, CC BY-SA 4.0, cropped.