On 9 April 2021, Libertax International Ltd was incorporated in the United Kingdom.
That date is useful as more than a corporate anniversary. It provides a fixed point from which to observe how quickly the environment for internationally mobile people and businesses changed.
The central lesson of the following five years was not that international structuring disappeared. It was that mobility remained possible while the cost of incoherence increased.
A visa, a company, a low tax rate or an offshore account could never answer the whole cross-border question on its own. Between 2021 and 2026, tax authorities, company registries, digital platforms, banks and regulators increasingly built systems that compare identity, residence, ownership, transactions and economic activity.
Key takeaways
- In April 2021, many of the rules that now shape international structuring had either not been announced or were not yet operational.
- The following five years combined continued jurisdictional competition with much stronger tax, ownership and transaction transparency.
- The durable practical requirement became coherence: residence, entity, activity, tax, banking and evidence must describe the same economic reality.
What could be known on 9 April 2021
The historical record must begin with what actually existed at the time.
Libertax International Ltd had been incorporated. DAC7 had already been adopted by the European Union on 22 March 2021, although its platform-reporting obligations were still a future implementation project. The OECD had spent years developing automatic exchange and international tax cooperation.
But several of the changes that later came to define the period were still unknown.
The UAE had not announced federal Corporate Tax. The OECD had not yet reached the October 2021 political agreement on the two-pillar solution. CARF did not yet exist. MiCA had not been adopted. Portugal had not announced the end of ordinary NHR access. The UK had not replaced the remittance-basis regime. Companies House had not received the 2023 powers that would move it toward identity verification and stronger registry integrity.
A retrospective becomes misleading if those later developments are written backwards into April 2021.
The point of an archive is to preserve that uncertainty.
The first shift: transparency moved closer to the transaction
DAC7 is a useful early marker.
Its significance was not that platform sellers suddenly became taxable because a new directive existed. The significance was that certain digital platforms became part of the information chain between economic activity and tax administrations.
That logic expanded.
The OECD developed reporting models for digital platforms and later designed CARF for crypto-assets. The EU adopted DAC8. Beneficial-ownership systems, company-register reforms and bank KYC standards continued to evolve through their own legal channels.
These regimes were not one coordinated law and they should not be described as if they were.
But together they reveal a common institutional trend: international activity increasingly leaves structured records in systems controlled by third parties.
The second shift: low-tax jurisdictions changed rather than disappeared
The period also challenged a different assumption — that tax competition would simply end as transparency increased.
It did not.
The October 2021 Pillar Two agreement created a new minimum-tax constraint for large multinational groups. Yet governments continued to compete through corporate rates, special regimes, immigration, infrastructure, legal certainty and business ecosystems.
The UAE is a clear example.
It opened more mainland activities to full foreign ownership, announced federal Corporate Tax in January 2022 and later implemented a Domestic Minimum Top-up Tax for in-scope multinational groups. None of those developments made the UAE equivalent to a high-tax European state. They did make the jurisdiction more rule-intensive.
Competition remained. The terms changed.
The third shift: regulatory access became an operating problem
Crypto showed this particularly clearly.
Dubai created VARA in 2022. The EU adopted MiCA in 2023. The policy direction was not “ban innovation” or “leave innovation alone”. It was to build regulated routes through which certain businesses could operate.
That distinction matters beyond crypto.
A legal entity is not the same as a functioning business. A licence is not a bank account. A visa is not tax residence. A tax-residence certificate does not automatically settle another country’s domestic residence claim. An offshore company does not by itself relocate the person managing it.
The five-year period repeatedly exposed the danger of treating one document as the answer to a multi-system problem.
What was misunderstood
The biggest misunderstanding was that increased transparency meant the end of legitimate international planning.
That conclusion confuses opacity with mobility.
People can still move. Businesses can still choose jurisdictions. Capital can still be allocated internationally. States still compete for founders, investment and talent.
What changed is the standard that a structure must survive.
An arrangement that depends on nobody comparing the records is weaker in a world where platforms report, banks collect source-of-funds information, registries verify identity and tax authorities exchange data.
The objective is not secrecy. It is a position that remains coherent when disclosed.
The strongest objection
There is a reasonable objection to presenting 2021–2026 as one direction of travel.
The period was not linear.
The United States introduced BOI reporting and then sharply narrowed it for domestic entities in 2025. Canada proposed a capital-gains inclusion-rate increase, deferred it and later abandoned it. Governments sometimes tighten rules and sometimes reverse them.
That objection is important because it prevents a simplistic story of ever-expanding regulation.
The more accurate conclusion is that policy changes faster and compliance systems are more interconnected. Both tightening and relaxation can invalidate an old memo.
What changed since April 2021
By the fifth anniversary of Libertax, several ideas that had once sounded specialised had become normal operating questions:
- Where is the individual actually tax resident?
- Where is a company effectively managed?
- Who is the beneficial owner and can that ownership be evidenced?
- What will a bank or payment provider see?
- What information will a platform, exchange or registry report?
- Is a preferential tax regime still available under current law?
- Does a regulated activity need more than a commercial licence?
- Can the tax return be reconciled with third-party data?
These are not separate worlds. They intersect.
That intersection is the professional terrain in which international structuring now operates.
What did not change
The underlying objective remained surprisingly stable.
International people and businesses still seek jurisdictions that provide a workable combination of freedom, legal certainty, taxation, market access, banking, mobility and quality of life.
The role of analysis is still to compare those systems.
The difference is that the comparison now has to be more complete.
The best jurisdiction on one variable can be the wrong jurisdiction once residence, tax, regulatory perimeter, banking and continuing obligations elsewhere are added to the picture.
The practical consequence
A robust international position should normally be built from the person and the real activity outward:
person → residence → activity → entity → flows → tax → banking → reporting → evidence.
Starting with a company product and working backwards encourages contradictions.
Starting with the facts makes it possible to choose a structure that can be explained consistently to tax authorities, banks, registries and counterparties.
That is the most useful five-year perspective from 9 April 2021.
The world did not become closed.
It became harder to operate internationally with a story that changes depending on who is asking.
Sources
- EUR-Lex — Directive (EU) 2021/514 (DAC7)
- OECD — Statement on a Two-Pillar Solution, 8 October 2021
- UAE Ministry of Finance — Corporate Tax
- OECD — International Standards on Tax Transparency
- EUR-Lex — Regulation (EU) 2023/1114 (MiCA)
- Companies House — Changes to UK company law, 26 October 2023
Disclaimer
This article is general historical and cross-border analysis, not legal, tax, investment or financial advice. Rules and administrative practice change over time. Any international structure or residence position should be tested against the current law and the specific facts before action is taken.
