ABSTRACT

This chapter illustrates some of the more prominent structures available in the tax havens. It seeks to assess the impact of such structures on human rights accountability when they are used in jurisdictions where they are not merely legal but where their use is actively encouraged both by government and the private sector. The chapter provides some of those tax haven offshore structures, showing how the generic form has been mutated to meet market needs: Generic corporations, Generic trusts and Foundations. It focuses more narrowly on the ways in which tax havens manipulate the generic corporate structure to promote concealment. The non-charitable purpose trust (NCPT) takes concealment to a new and dangerous level, by not simply hiding the identity of a beneficial owner, but by abolishing the concept of beneficial ownership altogether. As with a trust, a foundation exists in order to hold a fund, which can comprise any form of property.