What follows is a list of countries that said they are not going to sign the OECD treaties. These countries are omitted from the OECD page that lists the countries cooperating in various ways.
Ecuador (we offer banking in Ecuador) Russian Federation, Venezuela, Bolivia, Brazil, Cuba, Saudi Arabia, Oman, Abu Dabi, Qatar, Ukraine, Lithuania, Nigeria, North Korea, Iraq, Iran, Suriname. Ghana, Egypt, Jordan, Jamaica, Lebanon, Syria, Libya, North Korea, Yemen, Oman, Afghanistan, Pakistan, Romania, Bulgaria, Uzbekistan, Kazahkstan, Georgia, Azerbaljan, Turkmenistan, Peru, Paraguay, Thailand, Indonesia, Vietnam, and many African under developed nations.
One can see that there is some resistance (putting it mildly) to the OECD. Blacklisting all of these countries by the OECD will be hard and probably impossible. The OECD is pushing around and bullying those countries it can force into signing the tax treaties and those that can resist just resist.
We expect some countries that have said they will sign the OECD tax treaties will in the final analysis never do so. The OECD effort has been successful only in part. They seemed to hit the big tax havens, think low hanging fruit.
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Panama Legal, S.A. Law Firm - Trust Agreement Banking, law firm signatory service in Ecuador, Mexico, Costa Rica and Guatemala. http://www.panamalaw.org
Sooner or later most countries will realize it's not to their best interests to sign such agreements with "spending havens". For instance, what the USA are doing is akin to protectionism and bullying American investors to repatriate their money; also so that they can take a bigger chunk of their wealth in the form of taxes.
There are still plenty of "holes" in the TIEA web of agreements. In fact only 7-8% of the countries have TIEA's or DTA with the new Article 26 language for tax information sharing. Thus, there are still plenty of opportunities to incorporate and bank offshore. Nonetheless achieving "offshore privacy" is very much a moving target and one must remain vigilant of new treaties and agreements.
Malaysia is a good option also. They have 0% tax for holding companies and do not cooperate with the IRS. PM me details on these corporations.
I've seen a few posts from you about Malaysia. Do you offer any services in Malaysia, or just generaly have positive thought about Malyasia offshore system?