In 1983 the UK and US unilaterally abolished the existing double-taxation treaties with the BVI. These treaties had facilitated a trickle of offshore financial business to the BVI. The cancellations resulted in a shortfall in government revenue.
Having failed to have the treaties reinstated, the government moved to keep the BVI’s economy afloat. “Necessity is the mother of all invention and so it proved in this case,” says Lewis Hunte, QC, a Barbadian lawyer and former attorney general of the