What are the features of the English law that make it so indisposable to international finance and particularly offshore companies?

I've recently bumped into this passage when reading about Cyprus, which is sort of an offshore center for companies working on the Eastern European markets, particularly Russia and Ukraine:

There is no alternative to Cyprus as a jurisdiction. The tax system for holdings is far too advanced and flexible. The Netherlands and Luxembourg do contain some features, but those conditions are still not as favorable for investors. There is no direct matching. You cannot simply take a Cyprus company and replace it like a piece of Lego in Luxembourg. You would need to use several jurisdictions, with several layers of holding companies in order to achieve a cascading system of tax distributions.

Source: mondaq.com

From what I understand, Cyprus stands out precisely because it runs on English corporate law. But which major parts of the law help Cyprus surpass the Netherlands and Luxembourg? Why don't the Netherlands and Luxembourg (and other countries, really) simply copy them?

  • I don't have any evidence for this, so not an answer, but I would suppose that the Common Law (and its historical reliance on the idea of "equity" in civl cases and case law) is more appealing than the statutory system used in most of mainland Europe.
    – sharur
    Commented Nov 26, 2018 at 17:31

1 Answer 1


From the quote it’s not the fact that it uses English common law that makes it appealing - it specifically calls out the flexible Cypriot tax law.

Other countries don’t copy it because they assess that the gains they make from being more attractive to large financial business (both in tax and other dimensions) will not make up for the damage in other sectors of the economy. Tax law is a whole mess of economic and political trade offs.

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