Jurisdictions | Marensa Advisory

🇦🇪

United Arab Emirates

Free Zones · Financial Free Zones · Mainland · Offshore & Wealth Structures

350+

Entities Set Up

30+

Licences Delivered

Free Zones

RAKEZ

Ras Al Khaimah Economic Zone

Marensa Advisory's own registered home. Best-value UAE free zone with fast processing and flexible activity coverage.

100% foreign ownership
0% corporate & personal tax
Full profit repatriation
Wide activity range: trading, consulting, e-commerce, media
Good visa quota allocation

Best for: Professional services, consultancies, international trading firms, holding companies

Setup: 1–2 weeks

DMCC

Dubai Multi Commodities Centre

Dubai's flagship free zone. Premium address, deep commodities ecosystem and strong crypto-friendly positioning.

100% foreign ownership
Commodities, gold, precious metals trading
Crypto and digital assets (DMCC Crypto Centre)
Prestige Dubai address
Large international business community

Best for: Commodity traders, crypto firms, fintechs wanting Dubai presence

Setup: 1–3 weeks

IFZA

International Free Zone Authority

One of Dubai's fastest-growing free zones. Cost-effective licensing with broad activity scope and straightforward process.

100% foreign ownership
Competitive licensing costs
Multiple activities on one licence
Flexi-desk and physical office options
Fast-track processing available

Best for: Startups, SMEs, freelancers, cost-conscious businesses wanting a Dubai base

Setup: 1–2 weeks

Meydan

Meydan Free Zone

Central Dubai location with highly competitive pricing. Popular for digital, media and professional service businesses.

100% foreign ownership
Low annual renewal costs
Dubai address, Nad Al Sheba
E-commerce and digital activity coverage
Simple online application process

Best for: Digital entrepreneurs, content creators, e-commerce, professionals seeking low-cost Dubai licence

Setup: 1–2 weeks

Financial Free Zones — Regulated

DIFC

Dubai International Financial Centre

The UAE's leading financial hub. English common law jurisdiction with its own courts. Regulated by the DFSA (Dubai Financial Services Authority).

DFSA-regulated financial licences: Cat 1–4
Fund management, brokerage, payment services, capital markets
Investment manager (Cat 3C): USD 500K capital
Broker-dealer (Cat 1): USD 10M capital
Arranger/advisor (Cat 2/4): USD 150K capital
Crypto & digital asset tokens framework
Islamic finance structures
FinTech Hive accelerator programme

Best for: Asset managers, fund managers, brokers, fintech firms, family offices, payment service providers

Timeline: 3–5 months

ADGM

Abu Dhabi Global Market

Abu Dhabi's international financial centre. English common law, FSRA regulated. Particularly strong for family offices, private wealth and innovation-focused firms.

FSRA-regulated financial licences
Single Family Office (SFO) framework — lighter regime
Investment manager, fund manager, broker-dealer
Digital securities and cryptoasset authorisation
RegLab regulatory sandbox for innovative businesses
Access to Abu Dhabi sovereign wealth ecosystem
Increasingly competitive on cost vs DIFC

Best for: Family offices, private wealth managers, alternative asset managers, tech-adjacent financial firms

Timeline: 3–5 months

UAE Mainland

DET / ADDED

Dubai Mainland

Full access to the UAE domestic market and government contracts. Since 2021, 100% foreign ownership permitted in most sectors. No trading restrictions.

Trade directly with UAE market and government entities
100% foreign ownership in most commercial activities
No restriction on number of UAE visas
Physical premises required in most cases
Broader activity scope than free zones

Best for: Retail, healthcare, construction, F&B, businesses targeting UAE government contracts or UAE residents

Setup: 2–4 weeks

CBUAE

UAE Financial Licences — Mainland

Central Bank of the UAE (CBUAE) issues regulated financial licences for mainland-based payment and financial service providers.

Payment Token Services (Cat A/B/C)
Money Service Business (MSB) / Remittance
Stored Value Facility (SVF)
Retail Payment Services
Capital: AED 1M – 50M+ depending on category

Best for: Payment service providers, remittance companies, e-money issuers, fintech firms targeting UAE retail consumers

Timeline: 4–6 months

Offshore & Wealth Structures

RAK ICC

RAK International Corporate Centre — IBC

Ras Al Khaimah's offshore company authority. Offers International Business Companies (IBCs) with flexible structures, privacy protections and low costs.

International Business Company (IBC) formation
No requirement to file accounts or public beneficial owner register
No UAE corporate tax on foreign-source income
Flexible share structures (including bearer-style protected)
Can hold international assets, IP, and equity stakes
Registered Agent required (Marensa provides)

Best for: International holding structures, asset protection, IP holding, investment vehicles, cross-border transactions

Setup: 3–7 days

RAK Foundation

Ras Al Khaimah Foundation

A RAK ICC private interest foundation — a legal entity that owns assets in its own right, with no shareholders, designed for wealth planning and succession.

No shareholders — assets held by the foundation itself
Governed by a Council and a Charter
Beneficiaries designated privately (not on public record)
Holds assets: real estate, equities, cash, business interests
Civil law alternative to a trust structure
Perpetual existence — no forced distribution

Best for: Family wealth planning, multi-generational asset transfer, estate protection, philanthropic structures

Setup: 1–2 weeks

DIFC Trust

DIFC International Trust

A trust registered under DIFC Trusts Law 2018. Common law structure governed by DIFC's independent courts. Strong for international wealth planning.

Common law trust — settlor, trustee, beneficiaries
DIFC-regulated trustees (professional trustee companies)
DIFC Courts provide world-class dispute resolution
Forced heirship protection for UAE and non-UAE assets
Can hold real estate, equity, financial assets globally
Confidential — not on a public register

Best for: HNW individuals, business owners planning succession, expats with multi-jurisdiction assets, families seeking forced heirship protection

Setup: 4–8 weeks

Virtual Assets

VARA

Virtual Assets Regulatory Authority

Dubai's dedicated crypto regulator — the world's first. Covers the full spectrum of virtual asset activities. MVP licence available for phased launch.

Exchange, Broker-Dealer, Custodian, Lending/Borrowing
Advisory and Management services
MVP → FMP two-stage licensing pathway
Capital: AED 1M – 10M+ depending on activity
AML/CFT, cyber security and market conduct frameworks required
Applies to Dubai-licensed entities (not DIFC/ADGM)

Best for: Crypto exchanges, token issuers, digital asset managers, custody providers, DeFi-adjacent businesses

Timeline: 4–9 months

DIFC / ADGM

Digital Asset Frameworks

Both DIFC and ADGM have their own regulatory frameworks for digital assets, distinct from VARA and suitable for institutionally-oriented crypto businesses.

DFSA (DIFC): Crypto Token and Investment Token regimes
FSRA (ADGM): Digital Securities and Cryptoasset Authorisation
Common law framework — preferred by institutional counterparties
Can passport regulated status to other common law jurisdictions
Integration with DIFC / ADGM's broader financial ecosystem

Best for: Institutional digital asset managers, tokenised fund structures, security token issuers, crypto prime brokers

Timeline: 3–6 months

🇲🇺

Mauritius

GBC · Authorised Company · Trust · FSC Licences

46

Tax Treaties

~3%

Effective Tax Rate

Corporate Structures

GBC

Global Business Company

Mauritius's flagship international structure. Formerly known as GBC1. The primary vehicle for fund management, investment holding, and cross-border operations benefiting from the treaty network.

80% partial exemption on foreign-sourced income → ~3% effective tax rate
Access to 46 double tax avoidance treaties (India, SA, UAE, UK, France, China)
No capital gains tax · No withholding tax on dividends
At least 2 resident directors required (Marensa provides)
Must demonstrate substance: management and control in Mauritius
Can hold FSC financial licences (Investment Manager, VASP, etc.)

Best for: Africa & Asia investment holding, fund management, royalty & IP holding, VASP licensing, tax-efficient international structures

Setup: 4–6 weeks

AC

Authorised Company

Formerly GBC2. A lighter-touch Mauritius entity for businesses that do not conduct business with Mauritius residents and do not require tax treaty access.

Does not have access to Mauritius tax treaties
No requirement for resident directors
Lower annual fees and maintenance costs than GBC
Exempt from Mauritius income tax on foreign income
Registered Agent required (Marensa provides)
Simpler compliance and reporting requirements

Best for: Low-cost offshore holding, e-commerce, IP holding where treaty access is not required, simple cross-border structures

Setup: 2–4 weeks

Trust

Mauritius International Trust

A discretionary or fixed-interest trust governed by the Trusts Act 2001. Common law structure with strong asset protection features and Mauritius-based trustee.

Settlor and beneficiaries can be non-Mauritius residents
20-year perpetuity period (extendable)
Assets protected from forced heirship claims
Mauritius-licensed trustee required (Marensa coordinates)
Can hold shares in GBC, real estate, financial assets globally
Confidential: not on a public register

Best for: Family wealth planning, asset protection from foreign judgments, succession planning, holding GBC structures within a trust wrapper

Setup: 4–8 weeks

FSC Financial Licences (within GBC)

FSC

Investment Manager Licence

For firms managing portfolios or funds on behalf of clients.

Min. capital: USD 200,000
Responsible officer required
AML/CFT framework mandatory

Timeline: 2–4 months

FSC

Investment Dealer Licence

For brokerage and securities dealing activities.

Min. capital: USD 1,000,000
Full dealer or broker (non-underwriting) categories
Compliance officer and MLRO required

Timeline: 2–4 months

FSC

VASP Licence

Virtual Asset Service Provider licence — a cost-effective alternative to UAE-based VASP licensing.

Min. capital: USD 200,000
Covers exchange, custody, transfer, advisory
FATF-compliant AML/CFT required

Timeline: 2–4 months

FSC

Payment Intermediary

For businesses providing payment processing and intermediation services internationally.

Net assets requirement applies
Payment flow compliance framework required
Popular with cross-border fintech businesses

Timeline: 2–4 months

🇨🇦

Canada

FINTRAC · Money Service Business Licensing

FINTRAC

Regulator

Financial Licensing

MSB

Money Service Business Registration

A federal registration with FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), required for any business in Canada providing MSB-regulated services.

Foreign exchange dealing
Money transfers (domestic and international)
Virtual currency exchange and transfer
Cheque cashing and money orders
Prepaid payment product sales
Crowdfunding platform operation

Best for: Remittance companies, crypto exchanges, FX brokers, payment platforms operating in Canada or serving Canadian residents

Registration: 4–8 weeks

MSB

AML/CFT Compliance — Canada

All FINTRAC-registered MSBs must implement and maintain a PCMLTFA-compliant AML/CFT programme. Marensa builds and maintains this programme alongside the registration.

Written compliance policies and procedures
Compliance officer appointment
Risk assessment (Business Risk Assessment)
Customer identification and due diligence procedures
Record-keeping framework
Employee training programme
Ongoing compliance reviews (2-year cycle)

Mandatory for all MSBs — Marensa delivers the registration and the compliance framework as a single bundled engagement

Framework build: 4–6 weeks

🇸🇨

Seychelles

IBC · CSL · VASP Registration · Resident Director

FSA

Regulator

3–7 days

IBC Setup

Corporate & Regulated Structures

IBC

International Business Company

The Seychelles IBC is one of the world's most cost-effective offshore structures. Governed by the International Business Companies Act 2016, it is widely used for international holding and trading.

100% foreign ownership
No corporate tax on foreign-sourced income
No public beneficial ownership register
Minimal annual filing requirements
Flexible share structure, including bearer-style protections
Registered Agent required (Marensa coordinates)

Best for: International holding companies, asset protection vehicles, IP holding, cross-border trading, joint venture structures

Setup: 3–7 days

CSL

Company Special Licence

A hybrid structure combining the flexibility of an IBC with access to Seychelles tax residency and treaty benefits. The CSL pays a flat 1.5% tax on worldwide income and can access Seychelles double tax agreements.

1.5% tax rate on worldwide income
Access to Seychelles tax treaties (limited network)
Can trade both internationally and domestically
Requires local director and more substance than IBC
Regulated by the FSA (Financial Services Authority)
More credibility than IBC for banking and counterparty purposes

Best for: Businesses requiring a degree of tax residency, firms needing greater banking credibility, structures where IBC is too light

Setup: 2–4 weeks

FSA

VASP Registration

The Seychelles Virtual Asset Service Provider registration is one of the most accessible entry-level crypto licensing options globally — cost-effective and relatively fast, making it suitable for early-stage VASP operations.

Regulated by the Financial Services Authority (FSA)
Covers exchange, brokerage, transfer, custody and advisory services
AML/CFT programme required (FATF standards)
Fit-and-proper assessment of principals
Lower capital requirements than UAE or Mauritius VASP
IBC or CSL required as the underlying entity

Best for: Early-stage crypto exchanges, VASP startups testing the market, businesses seeking a cost-effective regulated base before scaling to UAE or Mauritius

Timeline: 6–12 weeks

Outsourced Services

Outsourced

Resident Director

Seychelles CSL structures and VASP licences require local directors. Marensa provides a named, qualified Resident Director based in Seychelles to satisfy the local presence requirement.

Satisfies local director requirement for CSL and VASP
Attends board meetings and signs resolutions
Maintains ongoing awareness of company activities
Annual service, billed on retainer

Required for CSL and VASP licensed entities

Ongoing monthly retainer

Outsourced

MLRO & AML/CFT Programme

All Seychelles VASP and CSL entities with financial activities must maintain a FATF-compliant AML/CFT programme. Marensa builds the framework and provides the outsourced MLRO if required.

AML/CFT policy suite tailored to VASP or financial activity
Business Risk Assessment
CDD/EDD procedures and sanctions screening
Outsourced MLRO with ongoing SAR/STR oversight
Annual compliance review

Required for all FSA-regulated entities and CSLs with financial activity

Build: 4–6 weeks | Ongoing retainer

🇸🇬

Singapore

MAS Licensing · Family Office · Payment Services · AML/CFT

MAS

Regulator

Financial Licensing

MAS

Capital Markets Services (CMS) Licence

Issued by the Monetary Authority of Singapore (MAS), the CMS licence is required for regulated capital markets activities including fund management, dealing in securities, and advising on corporate finance.

Type 1: Dealing in securities
Type 4: Advising on securities / investment advice
Type 9: Asset management (fund management)
Registered Fund Management Company (RFMC) — lighter regime for smaller managers
Licensed Fund Management Company (LFMC) — full licence
Min. base capital: SGD 250K (RFMC) to SGD 1M (LFMC)

Best for: Asset managers, fund managers, securities dealers, financial advisers seeking a Singapore-regulated base with APAC access

Timeline: 4–9 months

MAS

Payment Services Act (PSA) Licence

The Payment Services Act 2019 governs payment service providers in Singapore. Three licence tiers exist depending on transaction volumes and service types, including coverage of digital payment tokens (crypto).

Money-Changing Licence — FX only
Standard Payment Institution (SPI) — up to SGD 3M/month transaction volume
Major Payment Institution (MPI) — above SGD 3M/month
Covers: e-money, digital payment tokens, merchant acquisition, remittance
Digital Payment Token services (crypto exchange/custody) require MPI
AML/CFT programme mandatory for all tiers

Best for: Fintech payment firms, crypto exchanges, remittance businesses, e-money issuers targeting Singapore or APAC markets

Timeline: 6–12 months

Family Office & Wealth Structures

MAS / IRAS

Single Family Office — Section 13O / 13U

Singapore offers two fund tax exemption schemes for family offices: Section 13O (Onshore Fund Scheme) and Section 13U (Enhanced Tier Fund Scheme). Both allow fund income to be exempt from Singapore income tax.

13O: Min. AUM SGD 10M at application; SGD 20M within 2 years. At least 1 investment professional in Singapore.
13U: Min. AUM SGD 50M. At least 3 investment professionals (1 non-family). Higher local spending requirement.
Qualifying investments: equities, bonds, funds, real estate (via approved entities)
Fund must be managed by a Singapore-based fund manager (MAS licensed or exempt)
Annual MAS reporting required

Best for: UHNW families seeking Singapore base, families moving wealth from mainland China or broader APAC, multi-generational wealth structures

Setup: 3–6 months

MAS

AML/CFT & Regulatory Compliance

All MAS-regulated entities must maintain a robust AML/CFT programme compliant with MAS Notice PSN01/PSN02/SFA04-N02 and FATF standards. Marensa builds and maintains these programmes for Singapore-regulated clients.

AML/CFT policies and procedures (MAS Notice compliant)
Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) framework
Suspicious Transaction Report (STR) procedures to STRO
Sanctions screening (MAS, UNSC, OFAC)
Annual AML/CFT audit and review
Regulatory examination preparation

Mandatory for all MAS-regulated firms — Marensa delivers as a standalone engagement or bundled with the licensing application

Build: 6–10 weeks

🇭🇰

Hong Kong

SFC Licensing · VATP · MSO · Trusts · Family Office · AML/CFT

SFC

Securities Regulator

HKMA

Banking Regulator

Financial Licensing

SFC

Securities & Futures Commission Licence

The SFC issues licences for regulated activities in Hong Kong's securities and futures markets. Hong Kong is one of Asia's premier financial centres with access to Chinese capital markets and a deep institutional investor base.

Type 1: Dealing in securities
Type 4: Advising on securities
Type 9: Asset management (fund management)
Min. liquid capital requirements: HKD 3M (Type 1) to HKD 10M (Type 9)
Responsible Officers (ROs) required — fit-and-proper assessment
HKMA-regulated for banking and deposit-taking activities

Best for: Asset managers, fund managers, securities dealers seeking access to APAC institutional markets and China-adjacent investment flows

Timeline: 4–9 months

SFC / VATP

Virtual Asset Trading Platform (VATP) Licence

Hong Kong introduced a mandatory licensing regime for Virtual Asset Trading Platforms (VATPs) in 2023 under the Anti-Money Laundering Ordinance (AMLO). All crypto exchanges serving Hong Kong retail investors must be SFC-licensed.

Mandatory for platforms serving Hong Kong retail or professional investors
Regulated by the SFC under the AMLO framework
Covers spot trading of virtual assets
Derivatives on virtual assets remain under existing SFC licensing
Minimum paid-up capital: HKD 5M
Strict AML/CFT, cybersecurity and custody requirements

Best for: Crypto exchanges seeking access to Hong Kong's regulated market and institutional liquidity, especially those with China-adjacent strategies

Timeline: 6–12 months

HKMA

Money Service Operator (MSO) Licence

The MSO licence is issued by the Hong Kong Customs and Excise Department and is required for businesses conducting money changing or remittance services in Hong Kong. It is one of the most accessible financial licences in the city.

Covers money changing (FX) and remittance services
Issued by Customs and Excise Department (C&ED)
No minimum capital requirement
Fit-and-proper assessment of directors and controllers
AML/CFT programme mandatory under the Anti-Money Laundering Ordinance
Annual renewal required
Widely used by crypto OTC desks and remittance startups

Best for: FX money changers, remittance operators, crypto OTC desks, payment startups entering Hong Kong — cost-effective first regulated step before scaling to SFC

Timeline: 2–4 months

Trust & Wealth Structures

HK Trust

Hong Kong Trust

Hong Kong trusts are governed by the Trustee Ordinance (Cap. 29) and offer a common law trust structure with strong asset protection features. The Trust Law (Amendment) Ordinance 2013 introduced perpetual trusts, making Hong Kong trusts particularly suited to long-term family wealth planning.

Perpetual duration — no rule against perpetuities in HK since 2013
Common law structure: settlor, trustee, beneficiaries
Forced heirship protection for assets held in trust
Licensed trust company as trustee (HKMA-regulated)
Can hold HK and international assets: equities, real estate, business interests
Confidential — not on a public register
No gift tax, estate duty or capital gains tax in HK

Best for: UHNW families in Greater China seeking long-term succession planning, asset protection from foreign judgments, and a common law trust in a reputable APAC jurisdiction

Setup: 4–8 weeks

Family Office & AML/CFT

SFC / HKMA

Family Office Structures

Hong Kong introduced a dedicated family office tax concession regime in 2023. Single family offices managing a qualifying fund can access a 0% profits tax concession on qualifying investment income.

0% profits tax on qualifying investment income for eligible family offices
Min. AUM: HKD 240M (approx. USD 30M)
At least 2 full-time employees in Hong Kong
Fund managed by HK-based Type 9 SFC-licensed manager
Access to Chinese capital markets (Southbound Bond Connect, Stock Connect)
Strong banking infrastructure and professional services ecosystem

Best for: UHNW families with significant China exposure, families seeking a regulated Asia hub with Chinese capital market access

Setup: 3–6 months

SFC / AMLO

AML/CFT Compliance

All Hong Kong licensed entities (SFC Type 1, 4, 9, VATP) must maintain AML/CFT programmes compliant with the AMLO, SFC AML Guidelines, and FATF standards. Marensa builds and reviews these programmes for Hong Kong clients.

AML/CFT policies compliant with SFC AML Guidelines
CDD/EDD procedures and ongoing monitoring
PEP and sanctions screening framework
STR reporting to the Joint Financial Intelligence Unit (JFIU)
Annual AML/CFT audit
Regulatory examination preparation

Mandatory for all SFC-licensed entities and VATP licensees

Build: 6–10 weeks

🌐

Other Jurisdictions

Additional markets where Marensa has delivered mandates

Beyond our primary jurisdictions, Marensa has delivered mandates across a further range of markets. Speak to the team for details on any of these.

🇬🇧

United Kingdom

FCA Authorisation (EMI, PI, Investment Firm) · MSB Registration · AML/CFT Compliance · GDPR / UK GDPR

🇻🇬

British Virgin Islands

BVI Business Company (IBC) · Fund structures · Investment Manager Registration · Asset holding vehicles

🇱🇺

Luxembourg

AIFMD Structures · UCITS Fund Advisory · CSSF Registration Support · EU Regulatory Compliance

🇲🇹

Malta

MFSA Authorisation · VFA (Virtual Financial Assets) Framework · MiCA Readiness · EU Passporting

🇰🇾

Cayman Islands

Cayman Star Trust · Exempted Companies · Foundation Companies · Limited Liability Companies · Segregated Portfolio Companies

Need another jurisdiction?

We advise on structuring across 20+ markets. Contact the team with your specific requirement.

Speak to the Team

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