Choosing a Tax Haven – Legal System
English law is the preferred governing law for business transactions worldwide, as English law has a well-known, well-developed and reputable jurisprudence. In addition, because of the British Empire, English law is widespread as its former colonies have modelled their legal systems closely on English law. UK tax havens include the 14 British Overseas Territories (including the British Virgin Islands), and the three Crown Dependencies. The law of the United States is also largely derived from the English common law system (at both the federal and state levels).
English law is transparent and predictable, providing freedom of contract—a pro-business approach. In addition, under English law, there’s no implied overarching duty of good faith in commercial contracts (unlike in other jurisdictions). English commercial law is built on well-founded principles and provides predictability of outcome, legal certainty and fairness.
For all the reasons listed above, tax havens with legal systems based on English law are the most popular and desired. All the top 10 tax havens have English law as the foundation of their legal systems.
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