Tax·Luxury

Part II · Jurisdictions · No. 07

Marshall Islands

A sovereign Pacific nation operating one of the world's largest open registries through International Registries, Inc. The flag is on the Paris MOU white list, accepted broadly by port states, and used by a substantial share of the world's commercial-yacht fleet and large pleasure yachts.

Why this jurisdiction matters

The Marshall Islands operates an open ship registry through International Registries, Inc. (IRI), a private administrator under contract with the RMI government. By gross tonnage it ranked third in the world in 2025, behind Liberia and Panama, with just under 200 million GT. For luxury-yacht owners, RMI flag offers operational acceptance (Paris MOU white list), Maritime Labour Convention compliance, established yacht-specific procedures, and no taxation of vessel ownership.

The relevant tax regime

Registration or residency mechanics

Vessel flag: through IRI, with options for traditional registration or fast-track in many cases. Entity formation: RMI non-resident domestic corporations are commonly used as the registered owner; alternative entity structures (LLC, LP, trust) available.

Reporting and disclosure

The Economic Substance Regulations, 2018 impose substance requirements on resident entities carrying on defined relevant activities. CRS reporting through participating financial institutions. The RMI has no FATCA intergovernmental agreement with the U.S. (it does not appear on the Treasury list of IGA jurisdictions), so RMI financial institutions are subject to the FATCA regulations directly.

The substance question

RMI flag is widely accepted by port-state authorities (Paris and Tokyo MOU white lists; U.S. Coast Guard QUALSHIP 21 eligibility). Whether the economic-substance rules reach a non-resident domestic vessel-owning entity depends on its activities; pure holding entities face lighter requirements than active operating entities.

Recent changes

Economic Substance Regulations (2018) and continuing transparency reforms reflect OECD and EU pressure. The flag remains on the Paris MOU white list (check the annual list). Liberia overtook Panama as the largest registry in 2023, and the RMI holds third place. Status as of October 2026.

Common asset classes parked here

Primary Sources

  1. Republic of the Marshall Islands Maritime Act 1990.
  2. RMI Associations Law (corporate and partnership entities).
  3. RMI Economic Substance Regulations 2018.
  4. U.S. Treasury, FATCA agreements table (RMI not listed) — home.treasury.gov.
  5. International Registries, Inc. — register-iri.com.
  6. Paris MOU on Port State Control — parismou.org.

Reviewed October 2026