Flag theory – creating a holistic offshore strategy

Four flags for an international business, residence, citizenship, lifestyle

The flag theory is a highly vivid concept which has been developed more than sixty years ago. It describes the strategic approach of (in the figurative sense) planting flags in different countries to allocate different aspects of taxation, regulations and economic framework. The flags separate mainly these four aspects:

  • Business: Where to locate the business (headquarters) and its assets under economic, regulatory and low-tax considerations, including corporate bank accounts and developing a proper structure to reduce the corporate income tax burden and other business taxes, and to protect and safeguard the business assets,
  • Tax residency: Where to be individually taxed on wealth (including private bank accounts) and income by selecting the best (territorial) tax regime and tax treaty framework.
  • Citizenship, its burden and benefits, including considerations to get a second passport respectively dual citizenship to diversify private risks and to overcome limits on investment opportunities and travel restrictions.
  • Private lifestyle: Where to perpetually travel and stay in countries, places, and playgrounds with the most attractive environment, lifestyle, freedom, and privacy protection.

This core concept has been enlarged over the years, pseudo-refined with additional flags, but still provides the best starting point to create a holistic offshore strategy to find more opportunities, freedom, safety, privacy, wealth and lifestyle fun. On all four aspects, going where you are treated best is the pragmatic strategy of the nomad capitalist. 

Go where you’re treated best – after careful consideration and tax planning

Becoming non-resident in the home country, earn money and wealth offshore, arrange the residence in a tax compliance way, and to bank overseas in a foreign currency, requires an experienced tax counsel. The nomad trap, which means leaving the home country without having properly structured the business affairs to legally reduce or eliminate taxes, shows typically up when it is already too late.

It is important to understand, that ignorance of the law is no defense to tax authorities. Doing nearly everything right, can mean to do everything wrong. The well-established principle “never trust a local” means, that a local advisor in an offshore jurisdiction will always recommend his own sales products, without considering the investor’s home country legislation or alternative options.

PUGNATORIUS Ltd. aspires to give clients legal and tax advice from a professional distance to the products, jurisdictions and offshore agents. 

Location-independent legal and tax advice from Bangkok

PUGNATORIUS Ltd. is the Bangkok-based specialist provider of transactional legal and tax advice on foreign investments in Thailand.  Flag theory for the nomad capitalist: Go where you’re treated best.

The law firm has a long tradition and particular know-how to assist and advice offshore investors and cross-border transactions involving offshore jurisdictions on these seven offshore solutions:

  • Offshore legal and tax advice
  • Offshore company selection, formation, and maintenance 
  • Offshore bank account opening and maintenance
  • Offshore investment and disinvestment
  • Offshore nominee services and its risk structuring
  • Offshore FinTech and crypto asset protection
  • Offshore search and rescue services – when it is nearly too late

The scope of professional services is further explained at pugnatorius.com/offshore.


Disclaimer: A little knowledge is a dangerous thing. This low-resolution high-level outlook constitutes neither legal advice nor an attorney-client relationship. 

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