Marshall Islands LLC for Cyprus residents: a Delaware style chassis in the Pacific, and when it beats Seychelles

General information, not legal or tax advice. Your result depends on your specific facts; ENCC connects you with licensed advisers who confirm it in writing. The figures below are illustrative and are not a promise of tax savings.

The Marshall Islands rarely come up in the first conversation about offshore structures. They come up in the third or fourth, usually from someone in shipping, crypto or investment holding, and usually with a confident claim: Delaware-style law, no tax on foreign income, and a registry respected by the world's largest shipowners. All three statements are broadly true. What tends to get left out is how hard it is to bank a Marshall Islands entity, how the LLC version raises the same Cyprus classification question as a US LLC, and why the structure only makes sense for a narrow set of businesses.

This guide explains what a Marshall Islands (RMI) LLC or corporation is, how it is taxed at home, how Cyprus will look at it, what Germany does if you are leaving from there, who it fits, how to set it up, what you pay for, the banking reality, five cases with numbers, the most common mistakes and a long FAQ.

Part 1. The Marshall Islands as a corporate jurisdiction

The Republic of the Marshall Islands is a Pacific island state in free association with the United States. Its corporate registry is administered through a US-based maritime and corporate registry operator and is best known for ships: the RMI flag is among the largest in the world by tonnage. A large number of shipping companies listed in New York and elsewhere are RMI corporations, which says something about the predictability of its corporate law.

That law is modelled closely on Delaware. The Business Corporations Act expressly allows RMI courts to look to Delaware case law where RMI law is silent. For a lawyer this is attractive: the rules on directors' duties, shareholder rights and corporate procedure are familiar and tested.

The entity types

Non-resident domestic corporation

Character: a classic opaque company with shares, a board and officers
Typical uses: ship owning, holding, listed groups
Cyprus view: a company; what you receive is a dividend

Non-resident domestic LLC

Character: a flexible LLC governed by an operating agreement, on the Delaware model
Typical uses: investment vehicles, joint ventures, crypto structures
Cyprus view: uncertain, like a US LLC; see Part 3

DAO LLC

Character: an LLC whose governance can be partly or fully run by smart contracts and on-chain voting, recognised by RMI legislation since 2022
Typical uses: protocols and decentralised organisations with members in many countries
Cyprus view: uncertain; depends on structure and on whether it is for-profit

Part 2. How the Marshall Islands tax a non-resident entity

A non-resident RMI entity, meaning one that does not do business in the RMI, is not taxed by the RMI on income earned outside the RMI. There is no withholding on dividends paid to non-residents. In practice, almost every RMI entity owned by a foreigner is in this position.

Two caveats. First, the RMI introduced economic substance rules, and how they apply to pure service companies raises its own questions, which you clear with your registered agent before forming. Second, transparency has grown: the RMI keeps beneficial ownership information, and its financial institutions and entities fall under international reporting.

EU list position

The Marshall Islands is on neither EU Annex I nor Annex II after the 9 October 2026 update (it left the EU list in 2023), so Cyprus defensive measures aimed at EU listed jurisdictions do not target it now. Recheck at every February and October update.

CRS

The RMI participates in CRS (Ministry of Finance announcement, August 2025). Accounts held by an RMI entity whose controlling person is resident in Cyprus are reported to Cyprus. Plan on full visibility and declare everything.

Part 3. How Cyprus looks at an RMI entity

Corporation: clear

An RMI corporation is a company. Provided it is genuinely managed outside Cyprus and has no Cyprus permanent establishment, a dividend to a Cyprus Non-Dom carries 0% SDC on dividends and interest for Non-Dom, no income tax and 2.65% GESY up to the EUR 180,000 cap.

LLC: the same uncertainty as a US LLC

Cyprus has no published position on how it classifies LLCs, and advisers split. A single member RMI LLC managed by its member resembles a transparent vehicle; one with managers, distributions by resolution and separate books resembles a company. Plan on the transparent reading unless a Cyprus adviser confirms otherwise in writing, based on the operating agreement. If transparent, the profit is your business income, taxed at progressive rates with social insurance. If you need certainty, use a corporation instead.

Management and control

The decisive test, as with every foreign company: if the entity is managed and controlled from Cyprus, it is Cyprus tax resident and pays 15% corporate tax since 1 January 2026. A real board outside Cyprus, meetings and minutes outside Cyprus, and banking mandates that reflect this are essential.

Permanent establishment

An online business, including a crypto business, can have a permanent establishment in Cyprus if contracts are habitually negotiated and concluded there or a home functions as a fixed place of business. Trading from a laptop in Limassol for an RMI entity is exactly that pattern unless the decision-making genuinely sits elsewhere.

CFC

The Cyprus CFC rules (since 2019, ATAD) apply to Cyprus resident companies controlling low taxed foreign entities, not to individuals. An RMI entity under a Cyprus Ltd needs CFC analysis; one owned personally does not fall under the Cyprus CFC rules.

Crypto income in Cyprus

Since 1 January 2026, Cyprus taxes profits from the disposal of crypto assets (sale, exchange into another crypto asset, gift or payment with crypto) at a flat 8% under Article 20E of the Income Tax Law. Crypto losses offset only crypto gains in the same year. Mined crypto and other crypto income, such as tokens received for work, fall under the general rules. Get advice on your specific pattern. An RMI entity does not change the character of income you earn personally.

Part 4. If you are leaving Germany

While you are German tax resident, an RMI corporation or opaque LLC that you control is exposed to the German CFC rules (§§ 7 to 14 AStG) on passive income taxed below 15%, and an entity managed from Germany is a German taxpayer under § 10 AO. Form it only after your German residence has ended.

If you hold at least 1% in a corporation and were fully German tax resident for at least 7 of the last 12 years, § 6 AStG exit tax applies on departure. For German nationals, § 2 AStG extended limited liability for German nationals in the year of departure and the following 10 years if they move to a low tax country (Cyprus Non-Dom can count) and keep essential economic interests in Germany (German income above 30% or EUR 62,000, German assets above 30% or EUR 154,000; not in years with affected income up to EUR 16,500), applies through § 5 AStG to income routed through an interposed RMI entity. Map these tests with a Steuerberater before the move. More in Germany to Cyprus, step by step.

Part 5. Who the Marshall Islands fit

Ship owning and maritime

Why: the flag, the registry and the corporate law are built for it; lenders and charterers know RMI entities
Watch: Cyprus also has a strong tonnage tax regime; compare before choosing

Decentralised protocols and DAOs

Why: the DAO LLC gives legal personality and limited liability to members of a genuinely decentralised organisation
Watch: it does not turn a one person business into a DAO

Investment holding with a real board

Why: Delaware-style law, no tax on foreign income, no withholding on dividends
Watch: banking; many banks will not open accounts

Not a fit: solo service businesses

Why: management and permanent establishment point to Cyprus, banking is hard, and Stripe does not generally support it; check the current country list
Better: a Cyprus Ltd or self-employment

Part 6. Step by step

Residence first. Cyprus tax residence, Non-Dom claimed, previous residence closed.
Fact sheet. What the entity will hold or do, who decides, where contracts are concluded, how money flows.
Corporation or LLC. If you want dividend clarity in Cyprus, prefer a corporation. If you need LLC flexibility, get the Cyprus classification opinion first.
Substance check with the registered agent: do the RMI economic substance rules apply to your activity?
Board. Real directors outside Cyprus with defined authority. For a DAO LLC, governance documents and on-chain rules that genuinely distribute control.
Formation through the registry's authorised agent: articles, bylaws or operating agreement, registers, beneficial ownership information.
Banking with a thorough KYC file; expect several refusals and plan alternatives early.
Your services agreement if you work for the entity, at arm's length and declared in Cyprus.
Annual cycle. Annual fees and filings in the RMI, board meetings abroad, accounts, dividend resolutions, your Cyprus return.
Review at each EU list update and when your activity changes.

What you pay for

One-off cost components

Formation: the authorised agent's service and the registry's fees
Documents: articles and bylaws or operating agreement, apostilled sets for banks
Advice: Cyprus opinion (essential for an LLC), substance review, crypto or maritime specialist advice where relevant

Annual cost components

RMI: annual registry fee, registered agent, substance reporting where it applies
Governance: real directors outside Cyprus
Accounting and audit where required by banks, lenders or investors
Cyprus: your own return and annual review

Part 7. Banking: the real bottleneck

RMI entities are among the hardest to bank. Many European banks and EMIs decline them outright, and payment processors generally do not support them. What tends to work: banks that already serve maritime groups, some institutions in Switzerland, the UAE or Asia, and, for crypto structures, regulated crypto custodians and specialised EMIs. A shipping company with a charter contract and a lender is easy to explain; a one person RMI LLC selling online services is not. Plan banking before forming, not after.

Part 8. Five cases with numbers

Fictional people, simplified numbers: one Cyprus Non-Dom, no other income, all profit distributed. Taxes, not service prices. Not offers, not promises of savings.

Nikos, 52, shipowner, formerly Piraeus

Business: two dry bulk vessels, each in its own RMI corporation, managed by a ship management company
Structure: RMI corporations, board with maritime professionals outside Cyprus
Tax: dividends to Nikos with 0% SDC for Non-Dom, GESY within the cap
Lesson: this is what RMI was built for; compare with Cyprus tonnage tax before choosing

Daniel, 29, DAO founder, formerly Tel Aviv

Business: DeFi protocol with contributors in five countries, governance token holders voting on-chain
Structure: RMI DAO LLC for the protocol; Daniel's own income from the DAO declared in Cyprus
Lesson: the DAO LLC protects members of a genuinely decentralised organisation; Daniel still pays tax on what he personally receives

Ivan, 36, solo crypto trader, formerly Sofia

Business: trading from his laptop in Limassol
Temptation: an RMI LLC "so the gains are offshore"
Problem: the LLC is likely transparent in Cyprus, and if opaque, managed from Cyprus; banking almost impossible
Right path: get advice on how Cyprus taxes his personal trading pattern and declare it directly
Lesson: an RMI entity does not move a Limassol trader offshore

Helga, 58, German investor, formerly Hamburg

Business: holding of a stake in a German shipping KG and international equities
Problem: German source income and § 2 AStG; the RMI corporation would be an interposed company under § 5 AStG
Right path: Steuerberater review first; RMI holding only for non-German assets, after departure
Lesson: German income stays German, whatever the wrapper

Leo, 41, fund manager, formerly Zurich

Business: a small investment vehicle with five investors from four countries
Structure: RMI LLC with manager management and an independent board outside Cyprus
Lesson: multi-investor vehicles with real governance are a natural fit; check regulatory rules on fund management in each investor country

Part 9. EUR 100,000 of profit, three ways (illustrative)

RMI corporation, genuinely managed abroad

Tax: about EUR 2,650 GESY on the dividend; 0% SDC for Non-Dom
On top: board and RMI compliance costs

RMI LLC treated as transparent

Tax: progressive income tax up to 35% on the profit as your business income, plus social insurance and GESY
On top: RMI compliance for little benefit

RMI entity managed from Cyprus

Tax: EUR 15,000 corporate tax in Cyprus, GESY on the dividend, interest and penalties for undeclared years

Assumptions: one Non-Dom, full distribution, no other income, no German claim remaining. Not an offer and not a promise of savings.

Part 9b. The documents, stage by stage

Before formation

Structure memo: one or two pages explaining what the entity will do, who the members or shareholders are, who decides and why the RMI
Opinions: the Cyprus tax opinion (essential for an LLC), the agent's view on economic substance, specialist advice for maritime or crypto activity
Banking pre-check: written confirmation from at least one bank, custodian or EMI that it will consider the entity

For formation

Identity: certified passports and proof of address for members, shareholders, directors and managers
Corporate: articles of incorporation or certificate of formation, bylaws or operating agreement, consents of directors or managers, registers, beneficial ownership information
DAO LLC extras: the smart contract addresses, governance rules and the description of how members vote, as required by the DAO legislation

For banking

Company set: formation documents and certificate of good standing, apostilled
Business evidence: charter contracts and loan agreements for ships, investment memoranda for holdings, protocol documentation and treasury policy for DAOs
Your file: Cyprus residence proof, tax residence certificate, source of wealth

Every year

RMI: annual fee, registered agent confirmation, substance filing where applicable
Governance: minuted board or manager meetings outside Cyprus, distribution resolutions, approved accounts
Cyprus: your return, dividends declared with GESY, fees for your own work

Part 9c. Economic substance in practice

Like most international business centres, the RMI introduced economic substance regulations after EU and OECD pressure. They require entities carrying on certain relevant activities to show adequate substance, or to demonstrate that they are tax resident elsewhere. How a given activity is classified, and whether a pure services company is caught, is a question to settle with the registered agent before you form.

Two practical points. First, if your entity is managed and controlled from Cyprus, you may be tempted to argue that it is "tax resident in Cyprus" to satisfy RMI substance. That argument works in the RMI, but it confirms to Cyprus that the entity owes 15% there. Second, substance filings create a record of who manages the entity and where. Make sure that record matches what you tell Cyprus and your bank.

Part 9d. Banking and custody: the realistic paths

Maritime banking

Who: banks with shipping desks in Europe, Asia and the Middle East
What they want: vessel documents, charter parties, the ship manager's details, a lender relationship
Reality: RMI ship owning companies are routine for them

Holding and investment

Who: private banks in Switzerland, Singapore or the UAE, some brokers
What they want: substantial assets, a clear investment purpose, a board they can talk to
Reality: possible for larger holdings, rarely for small ones

Crypto and DAOs

Who: regulated crypto custodians, some specialised EMIs and fiat on-ramp providers
What they want: governance documentation, treasury policy, sanctions and AML controls, identified signers
Reality: workable, but conventional bank accounts remain rare

Online services

Who: very few providers
Reality: most EMIs and processors decline RMI entities; this is usually the point where a founder realises a Cyprus Ltd was the better tool

Part 9e. How a Cyprus enquiry unfolds

A CRS report from the RMI or from the bank's country shows an account with you as controlling person. Your Cyprus return shows dividends, or nothing. The Tax Department asks: what does the entity do, who manages it, where are decisions taken, what do you receive from it?

For a corporation with a real maritime board, the answer is straightforward and documented. For an LLC with you as sole member and manager, the Department may conclude either that the LLC is transparent, making its profit your income, or that it is a company managed from Cyprus and owing 15%. Either way, back tax, interest and penalties follow for the open years. The quality of your file decides which story is believed.

Part 9f. Germany in more depth

Classification

Germany classifies an RMI LLC through the resemblance test under the Federal Ministry of Finance letter of 19 March 2004. An RMI corporation is a corporation. A DAO LLC is uncharted territory and needs individual analysis.

Before departure

An RMI corporation, or an LLC classified as a corporation, that you control while German resident is a candidate for the CFC rules on passive income taxed below 15%, and for German taxation through the place of management under § 10 AO. Investment income, which is typical for holdings, is generally passive under the German rules.

At and after departure

§ 6 AStG taxes the latent gain on holdings of at least 1% if you were fully German resident for at least 7 of the last 12 years. For German nationals with essential economic interests in Germany, § 2 AStG can reach German source income for up to 10 years, and § 5 AStG extends it through interposed RMI entities. German shipping partnerships and German real estate are typical German assets that keep the § 2 tests alive.

Part 9g. Three more cases

Petra, 47, ship manager, formerly Bremen

Business: a minority stake in two RMI ship owning corporations alongside a Greek family
Problem: she also sits on the boards and lives in Limassol
Consequence: if the boards meet in Limassol with her as the decisive voice, Cyprus management becomes arguable
Solution: board meetings in Athens and London, majority of directors outside Cyprus, Cyprus tonnage tax compared as an alternative
Lesson: even classic RMI use cases need management discipline when a director lives in Cyprus

Ahmed, 34, NFT studio, formerly Cairo

Business: a studio of three people selling digital collectibles
Temptation: a DAO LLC
Problem: no real token governance, three founders deciding everything on a call
Right choice: a conventional company, possibly a Cyprus Ltd
Lesson: a DAO is a governance model, not a tax label

Clara and Jonas, 60 and 62, retirees, formerly Stuttgart

Assets: a securities portfolio and a rented flat in Stuttgart
Temptation: an RMI corporation to hold everything
Problem: German real estate stays German source; the flat keeps § 2 AStG relevant; the corporation adds § 5 AStG and annual cost
Right choice: personal holding as Non-Dom, German rental income declared in Germany, § 2 tests reviewed yearly
Lesson: retirees rarely need an offshore company

Part 9h. Decision checklist: is the RMI the right tool?

What is the activity?

Points to RMI: ships, genuine DAOs, multi-investor holdings
Points elsewhere: solo services, ecommerce, consulting

Who governs?

Points to RMI: a board or token holders outside Cyprus with real power
Points elsewhere: you, alone, in Limassol

Can it be banked?

Points to RMI: a bank, custodian or lender has confirmed interest in writing
Points elsewhere: you hope to "figure banking out later"

Do you need certainty in Cyprus?

Points to an RMI corporation: you want a clear dividend
Points to an LLC only with an opinion: you need LLC flexibility and accept the classification question

Part 9i. Shipping and Cyprus tonnage tax

Ship ownership is the use case where the RMI is strongest, and it is also the case where Cyprus offers its own serious alternative. Cyprus operates an EU approved tonnage tax system for qualifying ship owners, charterers and ship managers. Under it, the tax is computed on the net tonnage of the fleet rather than on profit, and dividends paid out of tonnage tax profits are treated favourably. For a Cyprus resident shipping entrepreneur, the honest comparison is therefore not "RMI versus Cyprus corporate tax at 15%" but "RMI flag and ownership versus Cyprus tonnage tax", or a combination in which the RMI company owns the vessel and a Cyprus ship manager provides real services.

The combination is common and legitimate, but it puts weight on the management question again. If the RMI owner is really run from the Cyprus office, its profit can be argued to be Cyprus taxable unless it qualifies for the tonnage regime itself. The qualifying conditions, including flag requirements and the EU's fleet composition rules, need a specialist maritime adviser. We do not treat the tonnage regime as an automatic shield; it is a regime you enter, with conditions you keep.

Part 9j. Getting out: exit routes from an RMI entity

Dissolution

When: the activity has ended, or the structure no longer fits
Steps: settle liabilities, distribute assets, file the certificate of dissolution through the agent
Cyprus side: a final distribution from a corporation is normally a dividend for you; document it and declare GESY

Redomiciliation

When: you want continuity of contracts, bank history or licences
How: RMI law allows continuation into another jurisdiction that accepts inbound redomiciliation, Cyprus included, subject to the Cyprus Registrar's conditions
Cyprus side: once continued, the company is Cyprus resident and taxed at 15%, with Cyprus audit and filing duties

Sale of the entity

When: ships or investment holdings are sold as companies rather than assets
Cyprus side: gains on the disposal of shares are generally outside Cyprus capital gains tax unless the company holds Cyprus immovable property; confirm with your adviser
Germany: if § 6 AStG applied at departure, check whether a deferral or instalment arrangement is affected by the sale

The exit you should avoid

What: simply stopping to pay the agent and letting the entity be struck off
Why it hurts: open bank accounts frozen, assets in limbo, no clean record for future banking or due diligence

Part 9k. Your first year, month by month

Months 1 and 2: design

Work: structure memo, Cyprus tax opinion, German exit review if relevant, choice between corporation, LLC and DAO LLC
Output: a written rationale you would be comfortable showing a tax inspector

Months 2 and 3: formation and governance

Work: formation through the authorised agent, appointment of directors or managers, bylaws or operating agreement, first board minutes outside Cyprus
Output: a complete corporate set, apostilled

Months 3 to 6: banking and custody

Work: applications to the institutions that pre-confirmed interest, answering questionnaires, interviews with directors
Output: at least one working account; a second as backup if the activity allows

Months 6 to 12: operation

Work: contracts signed by the entity, quarterly board meetings, bookkeeping, substance filing where applicable
Output: an audit file that grows with every decision

After year end

Work: approved accounts, distribution resolution, your Cyprus return with dividend and GESY, review of German § 2 AStG tests if they still run
Output: a clean first year that the bank and the Tax Department can follow

Part 9l. Questions to ask your registered agent before you sign

Agents differ widely in what they actually do. Before you commit, ask in writing, and keep the answers in your file.

Substance: does my planned activity fall under the RMI economic substance rules, and what filing do you prepare each year?
Directors: can you introduce directors or managers who will genuinely review and decide, and what is their professional background?
Banking: which institutions have opened accounts for entities like mine in the last year, and what did they ask for?
DAO LLC: what governance documentation do you require, and how do you handle changes to smart contracts?
Exit: what is your process for dissolution or continuation into another jurisdiction?
Records: where are the registers kept, and how fast can you deliver a certificate of good standing?

An agent who answers vaguely on substance or banking is telling you something about how your structure will hold up under questions from Cyprus. A good agent will also tell you plainly when an RMI entity is the wrong choice for you, and that answer is worth more than a quick formation.

Part 9m. A DAO treasury and a Cyprus resident contributor

A typical modern situation: you are a core contributor to a protocol whose DAO LLC is registered in the RMI. You live in Limassol, you receive tokens and stablecoins for your work, and you hold governance tokens yourself. Three separate questions arise, and they should not be blurred.

First, what are your payments? Tokens or stablecoins received for work are, in Cyprus, generally income from employment or from a business, depending on the relationship. They are taxable at progressive rates with social insurance and GESY. Non-Dom status does not change that; it covers dividends and interest, not pay for work.

Second, is the DAO LLC itself managed from Cyprus? If governance is genuinely on chain and distributed across many holders, the answer is usually no. If a small multisig of contributors, most of them in Limassol, takes the real decisions, the answer becomes arguable, and the Tax Department may look at the DAO's treasury income.

Third, what happens when you sell tokens? Since 2026 Cyprus taxes crypto disposal gains at a flat 8%; no gain is outside the tax net. Keep wallet records, transaction histories and valuations at the date of receipt. Without them, you will not be able to prove either the income you declared or the cost basis of what you sell later.

The DAO LLC protects the protocol and its members from unlimited liability. It does not decide your personal tax position in Cyprus, and it does not decide whether a permanent establishment exists where contributors work.

Part 10. Mistakes we see most often

Using an LLC and assuming dividend treatment.
Forming before checking banking. Months lost and an entity you cannot use.
A solo business in an RMI wrapper. Management and permanent establishment are in Cyprus.
Calling a one person company a DAO.
Ignoring substance rules.
Assuming invisibility. CRS reports.
Forming while still German resident.
Routing German income through it. § 2 and § 5 AStG.
No services agreement for your own work.
Not checking the EU list.

Part 11. Frequently asked questions

Does an RMI entity pay tax in the Marshall Islands?

A non-resident entity is not taxed by the RMI on income earned outside the RMI, and there is no withholding on dividends to non-residents.

Is the Marshall Islands on the EU blacklist?

No. It left the EU list in 2023 and is on neither annex as of October 2026.

Corporation or LLC?

For dividend clarity in Cyprus, a corporation. An LLC raises the same classification question as a US LLC.

What is a DAO LLC?

An RMI LLC whose governance can run through smart contracts and on-chain voting, giving members legal personality and limited liability.

Can I open a bank account?

Possibly, but it is the hardest of the common offshore jurisdictions. Plan banking before forming.

Can I use Stripe?

Generally not; check the current country list.

Will Cyprus know?

Assume yes. The RMI participates in CRS.

Can I be the director?

Formally yes; for tax, the entity then becomes Cyprus resident if you run it from Cyprus.

Do Cyprus CFC rules apply?

Not to an entity you own personally; potentially to one owned by a Cyprus company.

Is RMI good for crypto trading?

For a genuine multi-member protocol or fund, it can be. For a solo trader in Limassol, it rarely changes anything.

How does it compare to Cyprus tonnage tax for ships?

Both are used by shipowners; the right choice depends on the fleet, the lenders and where the management sits. Compare with a maritime adviser.

I am German. When can I form it?

After your German residence has ended and your Steuerberater has reviewed §§ 2, 5 and 6 AStG.

How long does formation take?

Formation itself is quick once due diligence is done. Banking and custody take far longer; plan months, not days.

Do I need to travel to the Marshall Islands?

No. Formation runs through the authorised agent, and meetings are held where directors are, outside Cyprus.

Can an RMI corporation own Cyprus companies?

Yes, but check Cyprus defensive measures at each EU list update and the substance of the holding.

What happens to my DAO LLC if the protocol fails?

The LLC can be dissolved under its governance rules and RMI law; members' liability stays limited if formalities were respected.

Is an RMI entity reported under CRS?

Yes. The RMI participates in the automatic exchange of information, and banks in other countries report accounts of RMI entities and their controlling persons to your country of tax residence.

Can I flag a yacht under the RMI through a company?

Yes, and many private yachts are. VAT, use in EU waters and Cyprus residence of the user all need separate analysis; the flag does not settle them.

Does the RMI have a public register of owners?

Member and shareholder names are generally not publicly filed, but beneficial ownership information is held and available to authorities. Confidentiality is not anonymity.

What if I am Romanian resident instead of Cypriot?

Romania applies its own CFC rules and its own place of effective management test. An RMI entity managed from Bucharest is at risk of Romanian residence. This guide does not cover Romanian residence in depth; ask a Romanian adviser.

The ENCC view

The Marshall Islands are a serious jurisdiction for serious use cases: ships, genuinely decentralised organisations and multi-investor holdings with real governance. For a solo founder in Limassol they add cost, banking pain and classification uncertainty without changing where the business is really run. ENCC prepares your fact sheet and connects you with authorised RMI agents, maritime and crypto specialists and Cyprus tax advisers who confirm the structure in writing.