Why is the British Virgin Islands a bigger source of foreign direct investment into China than the USA, the European Union and Japan combined? Why is there 10 times more investment from China in the Caymans Islands than there is in the USA? This paper argues that these flows represent the efforts of Chinese and foreign investors to reduce governance and measurement transaction costs. Investors avail themselves of efficient institutions in offshore centers that are absent locally. These institutional attractions include the ease of raising capital on foreign stockmarkets, access to reliable courts, and more flexible and sophisticated financial products. Existing explanations of these capital movements, characterizing them as criminal money or tax arbitrage, are insufficient. Evidence is drawn from government statistics, private legal advice and interviews in offshore financial centers.