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Top 5 SPV Jurisdictions for 2026: Where to Set Up, Banking, and Residency Considerations

  • Writer: Matthew Ivo
    Matthew Ivo
  • 3 days ago
  • 9 min read
Flags from various countries form a globe; text reads "Top 5 Countries to Set Up an SPV in 2026" on a dark blue background.

International trade has evolved from ancient exchange networks linking Mesopotamia, Egypt, China, and India to today’s highly digitised global supply chains. Yet one challenge remains constant: moving and managing funds across borders efficiently. Historical frictions such as currency volatility, payment delays, and reliance on major financial hubs still echo today, despite fintech innovations offering faster, more transparent transactions.

For businesses, family offices, and investment vehicles, selecting the right Special Purpose Vehicle (SPV) jurisdiction is critical in 2026. Factors such as banking access, residency requirements, regulatory credibility, and tax efficiency directly influence operational success and investor confidence.

This guide explores the top five SPV jurisdictions for 2026: Cayman Islands, British Virgin Islands (BVI), Ireland, Luxembourg, and Singapore - providing a clear overview of pros, cons, banking options for non-residents, and shared challenges. We also highlight how Interpolitan Money can help navigate these complexities and streamline SPV setup and banking across borders. Skip to section


What are SPV accounts and how do they work?

A Special Purpose Vehicle (SPV) account is a dedicated financial account used to fund temporary projects, isolate financial risk, and segregate transactions from the parent company. SPVs are commonly used by:

  • Family Offices

  • Property Developers

  • Investment Vehicles

  • Law Firms

SPV accounts are offered by both traditional banks and licensed Electronic Money Institutions (EMIs):

  • Banks provide standard legacy solutions.

  • EMIs offer flexible, digital-first services with 48-hour onboarding, instant payments, multi-currency support, and treasury integrations.

 

Most popular non-UK jurisdictions for SPV formation in 2026

 

  1. Cayman Islands

The Cayman Islands, located in the Caribbean Sea, are renowned for tax-neutral SPVs, offshore asset storage, and a well-established fund infrastructure. This makes them particularly popular with hedge funds, private equity firms, and ultra-high-net-worth individuals (UHNWIs).

Legal & corporate framework:

  • Under the Companies Act (As Revised), SPVs are typically incorporated as exempted companies, offering a flexible and internationally recognised corporate structure.

  • Only one director and one shareholder are required, with no residency restrictions or minimum share capital.


Why the Cayman Islands:


  • Fully tax-neutral: no corporate income, capital gains, withholding, or dividend taxes.

  • Rapid incorporation—often within 24 hours—and strong common law protections make it ideal for securitisation, structured finance, and aircraft financing.

  • Recognised globally for legal clarity, creditor protection, and flexibility in holding and financing assets.


Use cases: Cayman SPVs are frequently used for structured finance, securitisation, investment funds, aircraft and shipping finance, and cross-border asset holdings.

Considerations:


  • SPVs must declare that operations are conducted primarily outside the Cayman Islands.

  • While no statutory capital is required, issuing a nominal share capital (commonly USD 1,000) is standard practice to ensure legal clarity.


Cayman’s combination of tax neutrality, legal robustness, and operational flexibility makes it a leading offshore choice for international SPVs.



  1. British Virgin Islands (BVI)

The British Virgin Islands is a leading offshore jurisdiction for SPVs, especially for holding structures, investment funds, fintech ventures, and shipping registries, thanks to its simple incorporation process and stable legal framework.

Formation & legal framework:

  • Under the Business Companies Act, SPVs (often Restricted Purpose Companies or SPCs) are formed through licensed registered agents; public formation is not permitted.

  • Regulatory rules require the company name to include “(SPV) Ltd/ Limited” or “SPC.”


Why BVI:

  • Fully tax-neutral: no corporate income tax on offshore earnings.

  • Simple incorporation and operational flexibility, with no residency requirement for directors or shareholders.

  • Popular for holding, financing, and cross-border investment vehicles due to ease of use and international recognition.


Use cases: BVI SPVs are commonly employed for holding companies, securitisation, investment funds, fintech structures, and international shipping registries.

Considerations:

  • Local banking options may be limited; many SPVs use third-country banks.

  • Compliance with KYC, AML, and due diligence is required, with licensed agents playing a key role in ongoing governance.


BVI’s simplicity, confidentiality, and tax-neutral framework make it a strong offshore jurisdiction for international SPVs and holding structures.





  1. Ireland

Ireland is a leading jurisdiction for international SPVs due to its English-speaking environment, EU membership, transparent regulatory framework, and well-established SPV regime under Irish tax law.

Tax & regulatory framework:

  • Under Section 110 of the Taxes Consolidation Act 1997, an Irish SPV can achieve “tax neutral” status, meaning no corporate tax, VAT, or duties on qualifying transactions.

  • SPVs must be Irish-resident, hold qualifying assets (such as loans, mortgages, or leases), and comply with specific reporting and governance obligations.

Why Ireland:

  • Ireland’s EU membership provides credibility and seamless access to euro-denominated markets, making it highly attractive for institutional and cross-border investors.

  • The SPV regime is transparent and robust, offering investor confidence through well-defined regulatory and compliance requirements.

  • Suitable for “orphan” SPV structures, allowing asset isolation and bankruptcy remoteness when shares are held by independent trustees or foundations.

Use cases: Irish SPVs are commonly used for securitisation, structured finance, debt issuance, investment holding companies, and other cross-border structures.

Considerations:

  • Irish SPVs carry higher compliance obligations and operational costs compared with offshore jurisdictions.

  • Maintaining a registered office in Ireland is mandatory, and banks may require at least one EEA-resident director or authorised signatory.

Thanks to its tax-neutral framework, EU access, and regulatory transparency, Ireland is an ideal jurisdiction for SPVs serving institutional and cross-border investors.

4. Cyprus

Cyprus is emerging as a leading European hub for SPVs, especially for securitisation vehicles, structured finance, private equity, and alternative investment funds. The jurisdiction combines a modern legal framework, EU membership benefits, and highly competitive tax efficiency.

Legal & structural flexibility:

  • Under the Cyprus Special Purpose Vehicle Law of 2016, SPVs can be established as companies, offering full flexibility to suit various financial and investment structures.

  • Legal forms include private limited liability companies (Ltd), public limited companies (PLC), and partnerships, making Cyprus adaptable for a wide range of SPV uses.

Why Cyprus:

  • Fully aligned with EU law, Cyprus allows securitisation, structured finance, and cross-border asset-backed structures with confidence and transparency.

  • Supports “orphan” SPV models, where shares are held by independent trustees or foundations, ensuring asset isolation, ring-fencing, and bankruptcy remoteness.

  • Offers one of the most attractive corporate tax regimes in the EU (12.5%), alongside an extensive network of double tax treaties, making cross-border investment and fund flows highly efficient.

Use cases: SPVs in Cyprus are widely used for securitisation, structured credit, real estate and infrastructure funds, private equity, venture capital, and holding structures for international assets.

Considerations:

  • Tax treatment is favourable: profits in securitisation vehicles distributed via debt instruments are often tax-neutral, enhancing investor returns.

  • Governance and compliance requirements apply, including audits and regulatory oversight for publicly issuing SPVs.

Cyprus’s combination of legal flexibility, EU compliance, and highly attractive tax and treaty benefits make it an increasingly preferred jurisdiction for SPVs targeting institutional and cross-border investors.


5. Singapore

Singapore is APAC's most popular jurisdiction for SPV incorporation, especially for investment structures, private equity, venture capital, real estate, and cross-border financing. Its transparent legal system, pro-business environment, and strong regulatory framework make it a compelling option.

Legal and tax framework:

  • SPVs in Singapore are typically formed as private limited companies under the Companies Act.

  • Corporate tax is 17% on chargeable income according to the Income Tax Act, but companies receiving foreign-sourced, non-remitted income may benefit from favourable tax treatment, making certain SPVs akin to offshore entities.

  • For multinational structures, the Inland Revenue Authority of Singapore states that “economic substance” for tax relief can be assessed despite the SPV having minimal local footprint.

Advantages:

  • Strong regional presence and access to Asia‑Pacific markets - attractive for PE, VC, real estate, and cross-border investments.

  • Transparent legal, accounting, and regulatory compliance under Singapore law: annual filings, governance, and audits (if above thresholds) are standardised.

  • Good reputation and credibility compared with many offshore-only jurisdictions, making it easier to build relationships with banks, investors, and counterparties.

What to watch:

  • If the SPV is managed and controlled from Singapore, or income is remitted there, corporate tax rates may apply.

  • Regulatory and accounting obligations are more formal than in purely offshore jurisdictions, but this is often a worthwhile trade-off for credibility and stability.



Comparison table: residency, tax & banking‑focus for SPV jurisdictions

Jurisdiction

Legal / Tax Regime

Typical SPV Benefits

Key Trade‑Offs / Considerations

Cayman Islands

Exempted company or SPC under Cayman law, tax neutral.

Zero corporate tax, simple structure, rapid incorporation, confidentiality.

Minimal substance requirements; depends on offshore assets/business being external.

British Virgin Islands

BVI Business Companies Act regime; offshore SPV structures.

Quick incorporation, no residency requirement, zero offshore tax, strong secrecy.

Limited local banking; reliance on third-party or foreign banks; compliance & due diligence.

Ireland

Section 110 SPV under Irish tax law; EU-based.

Tax neutrality for qualifying SPVs, EU and euro‑market access, and regulatory transparency.

More administration, compliance, registered office requirements & regulatory scrutiny.

Cyprus

Cyprus Companies Law; SPVs often structured as private limited companies; favourable tax regime for non-resident activities.

Low corporate tax (12.5%), access to EU markets, strong treaty network, flexible SPV structures, EU investor credibility.

Substance requirements and management in Cyprus may trigger local tax; reporting and compliance obligations; careful planning needed for non-resident income.

Singapore

Private Limited Company under Companies Act; income taxed under Income Tax Act; favourable treatment for foreign‑sourced income under certain conditions.

Asia‑Pacific gateway, strong legal & accounting standards, credible regulatory environment, access to regional banking and investment markets.

Local substance and management might trigger tax, compliance, and accounting obligations higher than offshore havens.

The role of Interpolitan Money in supporting SPVs

Setting up an SPV is only the beginning. For non-resident owners, accessing reliable banking, managing documentation, and ensuring operational credibility are challenges.

Partnering with Interpolitan Money ensures your SPV can operate effectively across borders with the right substance, documentation, and financial infrastructure from day one.

Key benefits for SPVs and non-resident owners:

Rapid global onboarding:

A fast-tracked application process and international KYC team enable new SPV clients, including those with non-resident directors and complex structures, to open operational accounts within two days of approval.

Multi-currency capabilities:

Hold, convert, and manage 50+ currencies in a single account. Access live spot rates, with 24/7 embedded FX, and competitive forward contracts to reduce exposure and optimise margins.

Global payment network:

Securely send and receive high-value payments in 160+ countries. Operate across borders without the need for local bank accounts, with same-day settlements via SWIFT, SEPA and Faster Payments (UK & Channel Islands) and end-to-end transaction monitoring.

Segregated SPV accounts:

Create self-contained accounts for each legal entity with dedicated vIBANs. This strengthens governance, simplifies audits, ensures compliance across jurisdictions, and adds an extra layer of protection for both project-specific and central funds.

Global safeguarding and compliance:

All client funds are held in segregated accounts with Tier-1 financial partners, keeping your capital ring-fenced with 100% liquidity and no withdrawal restrictions. Interpolitan Money is licenced and regulated by the FCA (UK), DFSA (UAE) and FINTRAC (Canada).

Dedicated Relationship Management:

Work with a hand-picked sector specialist, experienced in cross-border SPV operations. Receive personalised support with day-to-day payments, FX, and treasury workflows.

Integrated treasury and liquidity tools:

Connect your accounts to automate reconciliations, monitor cash positions in real time, and optimise capital allocation across entities and currencies.

So, whether you’re acquiring commercial assets, funding developments, or managing rental income, an SPV account from Interpolitan Money helps you embrace opportunities without the admin.

To discover how Interpolitan Money’s SPV Accounts can help future-proof your buy-to-let operations, contact our team today for an introductory call.

 



FAQs: International SPV formations

  1. What is an SPV, and how does it work? A Special Purpose Vehicle (SPV) is a legal entity created to isolate financial risk, manage project-specific funds, and segregate transactions from the parent company. SPVs are commonly used by investment vehicles, family offices, law firms, and property developers.

  2. Which are the top SPV jurisdictions in 2026?


    The leading SPV jurisdictions are the Cayman Islands, British Virgin Islands (BVI), Ireland, Luxembourg, and Singapore. Each offers unique advantages in tax efficiency, banking access, regulatory transparency, and investor credibility.

  3. What factors should I consider when choosing an SPV jurisdiction?


    Key considerations include tax neutrality, banking availability, residency requirements, regulatory transparency, operational complexity, legal flexibility, and credibility with international investors.

  4. How do Cayman and BVI SPVs differ from EU-based SPVs like Ireland and Luxembourg?


    Cayman and BVI SPVs focus on tax neutrality, minimal compliance, and rapid incorporation, whereas EU SPVs provide regulatory transparency, access to euro-denominated markets, and stronger investor confidence, though with higher compliance obligations.

  5. Why is Singapore a strategic jurisdiction for SPVs in APAC?


    Singapore offers a transparent legal framework, favourable tax treatment for foreign-sourced income, access to regional markets, strong regulatory standards, and credibility with international investors, making it ideal for cross-border investment vehicles.

  6. What types of entities can SPVs be structured as?


    SPVs can take multiple legal forms depending on jurisdiction: exempted companies, restricted purpose companies (SPCs), private limited companies, securitisation undertakings, or fund vehicles—each tailored for specific financial or investment goals.

  7. Can non-residents open SPV bank accounts?


    Yes. With licensed agents or service providers like Interpolitan Money, non-residents can access SPV accounts globally, including multi-currency support, treasury integrations, and fast onboarding without local residency requirements.

  8. How does Interpolitan Money support SPV operations?


    Interpolitan Money streamlines SPV setup and banking across jurisdictions, offering rapid onboarding, segregated vIBANs accounts, multi-currency management, global payment networks, compliance monitoring, and dedicated relationship management for investors and operators.

  9. What are the common uses of SPVs?


    SPVs are typically used for securitisation, structured finance, private equity, venture capital, real estate, holding structures, debt issuance, and isolating financial risk for temporary or project-specific purposes.

  10. How do SPVs optimise international investment and operational efficiency?


    By isolating assets, simplifying cross-border transactions, providing tax-efficient structures, and enhancing investor confidence through regulated frameworks, SPVs enable smoother international capital deployment and risk management.


Disclaimer: This article is for general informational purposes only and does not constitute legal, tax, or company-formation advice. Interpolitan Money does not provide guidance on taxation, company setup, or choice of jurisdiction. You should always consult a qualified professional before making any decisions.



 
 
 
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Interpolitan Money Plc is authorised and regulated by the Financial Conduct Authority (“FCA”) to issue electronic money under the Electronic Money Regulations 2011. FRN 900413. Forward contracts and associated credit facilities are not regulated by the FCA. Interpolitan Money Plc registered office address 2 Leman Street, London, England, E1W 9US, a company incorporated under the laws of England and Wales, registration number 07666629.

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