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. The registry is the third-largest in the world by tonnage. 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 (mirroring Cayman) impose substance requirements for entities engaged in defined activities. CRS reporting through participating financial institutions. U.S. FATCA Model 1A IGA in force; U.S. account information reported.

The substance question

RMI flag is widely accepted by port-state authorities. Substance for the vessel-owning entity follows the Economic Substance regime; pure holding companies face lighter substance requirements than active operating entities.

Recent changes

Economic Substance Regulations (2018) and continuing transparency reforms reflect OECD and FATF pressure. The flag has remained on the Paris MOU white list throughout. IRI continues to expand service offerings and worldwide-office network.

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. FATCA Model 1A IGA between U.S. and RMI.
  5. International Registries, Inc. — register-iri.com.
  6. Paris MOU on Port State Control — parismou.org.

Reviewed May 2026