The Advantages of the Cyprus Tax System
|
|
- Gilbert Perry
- 6 years ago
- Views:
Transcription
1 The Advantages of the Cyprus Tax System Nicos S. Kyriakides Partner in Charge, Limassol Copenhagen April 2009 Cyprus Tax Reform Objectives Conformity to European Law and the Acquis Communautaire on Direct and Indirect Taxation Compliance with the Code of Conduct on Business Taxation and our commitment towards OECD requirements against harmful tax practices. Simplification and effectiveness of the tax system and more transparency Maintain and improve the competitive position of Cyprus in the international tax arena. 1
2 Interpretation and Tax Base Change of philosophy and the tax base Connecting the tax residence of the taxpayer with the source of income. Treatment of income derived from sources abroad under a new approach Interpretation and Tax Base Resident in the Republic When applied to an individual, means an individual who is present in Cyprus for a period or periods > 183 days in the year of assessment. 2
3 Interpretation and Tax Base Resident in the Republic When applied to a company, means a company whose management and control is exercised in Cyprus. Interpretation and Tax Base Management and Control There is no definition in the law Management and control in practice is considered to be exercised in: The place where the majority of the Board of Directors reside The place where the majority of the meetings of the Board take place and significant decisions are taken 3
4 Interpretation and Tax Base Permanent establishment means a fixed place of business through which the business of an enterprise is wholly or partly carried on and includes: Place of management Branch Office Factory Workshop Mine, oil or gas well, quarry or any other place of extraction of natural resources. Building site or construction or installation project or supervisory activities, provided they last more than three months. Imposition of Tax Resident in the Republic Tax is imposed on income derived or arising from sources both within and outside Cyprus. 4
5 Imposition of Tax Non-resident in the Republic Tax is imposed only on income derived or arising from sources within Cyprus. Taxation of individuals The Income tax rates for individuals for 2009 are: Up to % From to % From to % Above % 5
6 Taxation of individuals Other useful provisions are: Interest income subject to SDC 10% Dividend income subject to SDC 15% Pension income from services rendered abroad 5% Remuneration from salaried services to a non-resident employer for an aggregated period of more than 90 days exempt Ideal Jurisdiction Low internal taxes Well developed tax system Political and economic stability Well developed financial sector Use of double tax treaties Low or zero exit taxes (withholding taxes) Ability to create substance. 6
7 Basic Advantages of Cyprus Corporate tax at 10% Exemption of dividend income (subject to conditions) Exemption of overseas PE profits (subject to conditions) Exemption of profits from disposal of securities Extensive network of double tax treaties Use of EU Directives Unilateral credit relief Low or zero withholding taxes. Corporation Tax Rates Companies 10% (Lowest in EU) Ship management companies 4,25% (or Tonnage tax) 7
8 Taxation of Dividends Dividends are exempt from corporation tax Dividends received by a person (individual or corporate) resident in the Republic are subject to Special Defence Contribution (SDC) at 15%. However, for companies there are exemptions. Taxation of Dividends Exemptions (a) Dividends received by a resident company, or a nonresident company which maintains a permanent establishment in the Republic from a company which is non-resident in the Republic and of which at least 1% of the share capital is held. are exempt from SDC 8
9 Taxation of Dividends Exemption (a) The exemption does not apply if the non-resident company paying the dividend: engages directly or indirectly by more than 50% in activities that lead to investment income and the overseas tax burden on its income is significantly lower than the Cyprus tax burden. (in practice less than 5%) Taxation of Dividends Exemptions (b) Dividends paid by a resident company to another company, which is also resident in the Republic are exempt from SDC. 9
10 Taxation of Interest Interest earned from financing activities is taxed as ordinary business income at a rate of 10% If interest does not qualify as business income, then: 50% is exempt from corporation tax and the remainder is taxed at a rate of 10% (effective rate 5%), and The gross amount of interest received is subject to SDC at a rate of 10%. Taxation of Royalties Intellectual Property Rights etc. No tax is withheld on royalty premiums payable to a non-resident, when the right is granted to a Cyprus entity for use outside the Republic Tax at 10% is withheld when the right is used in the Republic, provided: There is no DTT in place which provides for a lower rate. and The royalties are not paid to another EU resident (subject to the conditions of the EU Interest/Royalties Directive). 10
11 Taxation of Overseas PE Profits Profits from a Permanent Establishment abroad are exempt from tax irrespective of the existence of a DTT The exemption does not apply if the Overseas PE: engages directly or indirectly by more than 50% in activities that lead to investment income and the overseas tax burden on its income is significantly lower than the Cyprus tax burden. (in practice less than 5%) If loss relief in previous years recapture rules apply. Profits from Disposal of Securities Profits or gains from the disposal of Securities are exempt from tax Irrespective of whether the profit or gain is of a revenue or capital nature Securities means shares, bonds, debentures, founder s shares and other securities of companies or other legal persons, incorporated under a law in the Republic or abroad and options thereon 11
12 Profits from Disposal of Securities Based on an interpretation Circular issued by the Commissioner on 17/12/2008, securities also include short positions on titles, futures/forwards on titles, swaps on titles, depositary receipts on titles such as ADRs and GDRs, rights of claim on bonds and debentures but not including rights on interest, index participations only if they result in titles, repurchase agreements or Repos on titles, units in open-end or closed-end collective investment schemes Shipping Operations According to Merchant Shipping Laws: No tax on profits from the operations of a Cypriot registered vessel or on dividends from a Cypriot ship owning company No capital gains tax on the sale or transfer of a Cypriot registered vessel or the shares of the Cypriot ship owning company No income tax on the emoluments of officers or crew on board a Cypriot registered vessel 12
13 Ship Management Companies According to Merchant Shipping Laws: Ship management services means crewing, technical and commercial management of ships Companies which satisfy the conditions may elect to be taxed either: At reduced tonnage tax (25% of amount calculated) on the ships managed by the company (Cyprus flag or foreign flag), or At the special rate provided in the Income Tax Law for ship management activities of 4,25% Use of Double Tax Treaties Cyprus has an extensive network of Treaties for the Avoidance of Double Taxation with more than 40 countries Covers most of Central and Eastern Europe and Russia 13
14 Double tax treaties Austria Belarus Belgium Bulgaria Canada China CIS * Czech Republic Denmark Egypt France * CIS replaced by treaties with Armenia, Kyrgyzstan, Tajikistan, Ukraine and Uzbekistan Germany Greece Hungary India Ireland Italy Kuwait Lebanon San Marino Malta Mauritius Moldova Norway Poland Qatar Romania Russia Slovakia South Africa Syria Sweden Thailand Seychelles U.K. United States Yugoslavia Treaties with other countries under negotiation Algeria Armenia Bahrain Kazakhstan Finland Indonesia Shrilanka Malaysia Bangladesh Australia Lithuania Latvia Italy Estonia Brazil Georgia Spain Bangladesh Brazil Gabon Switzerland Zambia Jordan Iceland Spain Ukraine Israel Libya Morocco Mexico Netherlands Pakistan Portugal Turkmenistan Yemen United Arab Emirates Iran Vietnam Uzbekistan 14
15 Cyprus Denmark DTT Main provisions Withholding taxes in Denmark: On dividends 10% (15% if <25% of the voting power) On interest 10% On royalties 0% Permanent establishment: defined as a branch, place of management, office, factory, workshop, a mine, an oil or gas well, a quarry or any other place of extraction of natural resources. Includes a building site or construction or installation project but only if it last for more than six months. Adoption of EU Directives A. Parent/Subsidiary Directive No withholding tax on payment of dividends No transitional period immediate effect No minimum participation/shareholding No minimum holding period Dividends are exempt subject to conditions Tax credit for both the tax withheld abroad and the underlying tax 15
16 Adoption of EU Directives B. Interest/Royalties Directive No withholding tax on interest paid to non-residents No transitional period immediate effect 25% minimum participation/shareholding required in the case of royalties No minimum holding period Interest taxed depending on nature Royalties are subject to corporation tax Tax credit for Tax Withheld abroad Adoption of EU Directives C. Merger Directive Copied into local legislation Effective from 1 January 2003 Applies to any reorganization Merger Division (including partial divisions) Transfer of assets Exchange of shares Involves companies resident and not resident 16
17 Unilateral credit relief for tax withheld abroad Irrespective of the existence of a DTT credit relief is granted for tax withheld abroad in respect of income derived from a foreign country, which is taxable in Cyprus against tax payable in Cyprus in respect of such income The relief shall not exceed the tax withheld abroad Withholding tax rates No withholding tax on dividends No withholding tax on interest No withholding tax on royalties for use of the rights outside Cyprus 10% withholding for use of the rights in Cyprus (subject to DTT & EU Directive) 5% on films (subject to DTT & EU Directive) 17
18 Other important provisions Tax losses can be carried forward indefinitely Group relief provisions Tax Planning Ideas 18
19 Tax planning ideas Maximum Cyprus tax 10% Danish Shareholder Nil withholding tax Cyprus Subsidiary Cyprus corporate tax 10%. Tax planning ideas Holding Company Treaty subsidiary Danish Ultimate Holding Co Cyprus Holding Co EU subsidiary At least 1% shareholding Dividends exempt from tax (subject to conditions) No withholding tax on dividends to non resident shareholders Wide Cyprus DTT network EU Parent Subsidiary Directive Result = 0% tax in Cyprus 19
20 Tax planning ideas Outbound Investments Danish Investor Co Investment in Non EU No Treaty Cyprus Holding Co Investment in a country with no DTT with Denmark and Non EU Or better DTT with Cyprus Investment through Cyprus At least 1% shareholding Dividends received by Cyprus holding Co exempt from tax (subject to conditions) or Credit relief No withholding taxes on payments to Danish Investor Tax planning ideas Inbound investment Investor Non EU No Treaty Danish Subsidiary Cyprus Holding Co Investor from a country with no DTT with Denmark Or Cyprus-Denmark DTT better Investment through Cyprus At least 1% shareholding Dividends received by Cyprus holding Co exempt from tax (subject to conditions) No withholding taxes on payments out of Cyprus. 20
21 PE in Denmark Tax planning ideas Holding Company Cyprus Company PE in Denmark Use of PE article of DTT to escape taxation in country of operations (under the DTT with Denmark PE profit is exempt in Denmark if building site or construction or installation project lasting less than 6 months) Tax exempt profits in Cyprus if PE project exceeds 3 months No withholding tax on dividends to holding company Result = 0% tax Tax planning ideas Employment Company Parent Co Danish Operating Co Cyprus Employment Co Cyprus company employs staff Charges at cost plus Profits taxable in Cyprus at 10% Profits reduced in operating country Employee costs reduced as employees pay less tax and S.I. Contributions * Employees exempt from tax in Cyprus. * Depends on nationality of employees and rules of operating country 21
22 Tax planning ideas Royalty Company (outbound) Danish Licensor Co Non EU or no DTT Operating Co Royalty payable Cyprus Royalty Co Royalty receivable Profits reduced in operating country Use of treaty network Credit relief in Cyprus for WHT in operating country if any Small margin taxable in Cyprus at 10% No withholding taxes on payments out of Cyprus. Tax planning ideas Royalty Company (inbound) Non EU or No DTT Licensor Co Danish Operating Co Royalty payable Cyprus Royalty Co Royalty receivable Profits reduced in Denmark No WHT in Denmark based on DTT Small margin taxed at 10% in Cyprus No withholding taxes on payments out of Cyprus. 22
23 Tax planning ideas Financing Company Haven Co Danish Operating Co Interest payable Cyprus Financing Co Interest receivable Profits reduced in operating country (Danish) 10% WHT in Denmark based on DTT (may be reduced to 0% under the EU Interest and Royalties Directive) Small margin taxable in Cyprus at 10% Credit for WHT in Denmark if any No withholding taxes on payments out of Cyprus. Tax planning ideas Ship management company Controlling company PE Abroad Cyprus Ship Man Co Vessels Special tax on profits from ship management services Employee costs reduced as employees pay less tax and S.I. * 90 days rule No tax on profits of PE subject to conditions No withholding taxes on payments out of Cyprus. Vessels * Depends on nationality of employees and rules of operating country 23
24 Tax planning ideas Trading in Securities Profit is exempt from tax Cyprus Trading Co Use of double tax treaties No withholding tax on payments out of Cyprus Buy Securities Sell Securities Result = 0% tax in Cyprus Tax planning ideas Non Resident Trading Company Cyprus Trading Co Managed and controlled outside Cyprus Exempt from tax in Cyprus Non resident Cyprus registered company Buy products Sell products Use of EU VAT number and reputation Result = 0% tax in Cyprus 24
25 In Summary Modern tax regime acceptable by EU and OECD Lowest corporate tax rate in Europe Added commercial value and benefits due to ability to register for VAT Tax breaks for expatriates. Offers many opportunities for effective tax planning Result Respectable & Competitive international business location 25
26 Thank You For more information you may contact: Nicos S. Kyriakides Member of the Board of Directors In Charge of Limassol Office Deloitte Ltd Tel: Fax: Mob : nkyriakides@deloitte.com Web: Deloitte. Maximos Plaza, Tower 1, 3 rd Floor 213, Arch. Makariou III Ave. CY-3105 Limassol, Cyprus P.O.Box 58466, CY-3734 Limassol, Cyprus 26
Contents. Andreas Athinodorou Managing Director International Tax Planning
Seize the advantage of our expertise Technical Newsletter This publication should be used as a source of general information only. For the specific applications of the Law, professional advice should be
More informationTechnical Newsletter. The Cyprus Holding Company. Seize the advantage of our expertise. Contents. Seize the Aspen advantage
Seize the advantage of our expertise Technical Newsletter This publication should be used as a source of general information only. For the specific applications of the Law, professional advice should be
More informationCyprus New Double Tax Treaties Become Effective
Seize the advantage of our expertise Cyprus New Double Tax Treaties Become Effective Cyprus Double Tax Treaty (DTT) network has been expanded with four new agreements with Lithuania, Norway, Spain and
More informationDouble Tax Treaties. Necessity of Declaration on Tax Beneficial Ownership In case of capital gains tax. DTA Country Withholding Tax Rates (%)
Double Tax Treaties DTA Country Withholding Tax Rates (%) Albania 0 0 5/10 1 No No No Armenia 5/10 9 0 5/10 1 Yes 2 No Yes Australia 10 0 15 No No No Austria 0 0 10 No No No Azerbaijan 8 0 8 Yes No Yes
More informationCyprus - The gateway to global investments
Cyprus - The gateway to global investments Why Choose Cyprus for International Business Activities? Cyprus has long been established as a reputable international financial centre, the ideal bridge between
More informationTax Planning and the Cyprus Holding Company
Anastasios Antoniou LLC s Corporate Practice has been selected as the Recommended Firm for Corporate Law in Cyprus by Global Law Experts in 2010 Tax Planning and the Cyprus Holding Company Information
More informationCyprus has signed Double Tax Treaties (DTTs) and conventions with 61 countries.
INFORMATION SHEET 14 Title: Cyprus Double Tax Treaties Authored: January 2016 Updated: August 2016 Company: Reference: Chelco VAT Ltd Cyprus Ministry of Finance General Cyprus has signed Double Tax Treaties
More informationCyprus Tax Guide for Investors
Cyprus Tax Guide for Investors Invest in Cyprus Invest in Us CONTENTS Cyprus: An international business & investment center Tax highlights Other related useful information 2 4 10 CYPRUS: AN INTERNATIONAL
More informationRomania Country Profile
Romania Country Profile EU Tax Centre March 2014 Key tax factors for efficient cross-border business and investment involving Romania EU Member State Yes Double Tax Treaties With: Albania Algeria Armenia
More informationCyprus tax laws and Cyprus-Ukraine tax treaties issues: peculiarities of application, optimization in taxation
Cyprus tax laws and Cyprus-Ukraine tax treaties issues: peculiarities of application, optimization in taxation Marios S Andreou Partner Taxation Services, Nicosia, Cyprus Limassol, Slide 1 Foreign Direct
More informationTax Newsflash January 31, 2014
Tax Newsflash January 31, 2014 Luxembourg s New Double Tax Treaties As of 1 January 2014, Luxembourg further enlarged its double tax treaty network with the entry into force of the new double tax treaties
More informationSlovakia Country Profile
Slovakia Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Slovakia EU Member State Double Tax Treaties Yes With: Australia Austria Belarus
More informationCYPRUS HOLDING COMPANIES
CYPRUS HOLDING COMPANIES CONTENTS PREFACE... OUR ORGANIZATION... 3... 5... 7 CONFIDENCIALITY CYPRUS 1 CYPRUS HOLDING COMPANIES DOUBLE TAX TREATIES... 8... 9 WITHHOLDING TAXES ON ICOMING DIVIDENDS... 11
More informationSetting up in Denmark
Setting up in Denmark 6. Taxation The Danish tax system for individuals rests on the global taxation principle. The principle holds that the income of individuals and companies with full tax liability
More informationRomania Country Profile
Romania Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Romania EU Member State Yes Double Tax Treaties With: Albania Algeria Armenia
More informationTurkey Country Profile
Turkey Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Turkey EU Member State Double Tax Treaties With: Albania Algeria Australia Austria
More informationAustria Country Profile
Austria Country Profile EU Tax Centre March 2014 Key tax factors for efficient cross-border business and investment involving Austria EU Member State Yes Double Tax Treaties With: Albania Algeria Armenia
More informationTurkey Country Profile
Turkey Country Profile EU Tax Centre June 2018 EU Tax Centre June 2018 Turkey Key tax factors for efficient cross-border business and investment involving Turkey EU Member State Double Tax Treaties No
More informationCYPRUS COMPANIES INFORMATION
CYPRUS COMPANIES General Type of entity: Private Type of Law: Common Shelf company availability: Our time to establish a new company: 15 days Minimum government fees (excluding taxation): Not applicable
More informationCyprus has signed Double Tax Treaties (DTTs) and conventions with close to 60 countries.
INFORMATION SHEET 14 Subject: Cyprus Double Tax Treaties Authored: January 2016 Updated: February 2016 Company: Reference: Costas Tsielepis & Co Ltd Cyprus Ministry of Finance General Cyprus has signed
More informationBelgium Country Profile
Belgium Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Belgium EU Member State Double Tax Treaties Yes With: Albania Algeria Argentina
More informationAPA & MAP COUNTRY GUIDE 2018 UKRAINE. New paths ahead for international tax controversy
APA & MAP COUNTRY GUIDE 2018 UKRAINE New paths ahead for international tax controversy UKRAINE APA PROGRAM KEY FEATURES Competent authority Relevant provisions Types of APAs available Acceptance criteria
More informationLithuania Country Profile
Lithuania Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Lithuania EU Member State Yes Double Tax Treaties With: Armenia Austria Azerbaijan
More informationInternational Taxation
International Taxation 2015 www.epwcy.com 1. Tax Planning through Cyprus Cyprus is consistently voted as the most attractive European tax regime by major business organizations and tax professionals across
More informationSwitzerland Country Profile
Switzerland Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Switzerland EU Member State No. Please note that, in addition to Switzerland
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Czech Republic EU Member State Yes Double Tax Treaties With: Albania
More informationFinland Country Profile
Finland Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Finland EU Member State Double Tax Treaties With: Argentina Armenia Australia
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Czech Republic EU Member State Yes Double Tax Treaties With: Albania
More informationSwitzerland Country Profile
Switzerland Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Switzerland EU Member State No. Please note that, in addition to Switzerland
More informationBelgium Country Profile
Belgium Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Belgium EU Member State Double Tax Treaties Yes With: Albania Algeria Argentina
More informationReal Estate & Private Equity workshop
Real Estate & Private Equity workshop Moderator: Panelists: Joseph Hendry, Managing Director, Brown Brothers Harriman Gautier Despret, Senior Manager, Ernst & Young Patrick Goebel, Counsel, Allen & Overy
More informationCyprus has signed Double Tax Treaties (DTTs) and conventions with 61 countries.
INFORMATION SHEET 14 Subject: Cyprus Double Tax Treaties Authored: January 2016 Updated: January 2017 Company: Reference: Costas Tsielepis & Co Ltd Cyprus Ministry of Finance General Cyprus has signed
More informationCzech Republic Country Profile
Czech Republic Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Czech Rep. EU Member State Yes Double Tax With: Treaties Albania Armenia
More informationLatvia Country Profile
Latvia Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Latvia EU Member State Double Tax Treaties With: Albania Armenia Austria Azerbaijan
More informationGuide to Treatment of Withholding Tax Rates. January 2018
Guide to Treatment of Withholding Tax Rates Contents 1. Introduction 1 1.1. Aims of the Guide 1 1.2. Withholding Tax Definition 1 1.3. Double Taxation Treaties 1 1.4. Information Sources 1 1.5. Guide Upkeep
More informationFOREWORD. Cyprus. Services provided by member firms include:
216/17 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
More informationMalta Country Profile
Malta Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Malta EU Member State Yes. Double Tax Treaties With: Albania Australia Austria
More informationCroatia Country Profile
Croatia Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Croatia EU Member State Double Tax Treaties With: Albania Armenia Austria Azerbaijan
More informationT H E C Y P R U S H O L D I N G C O M P A N Y A s e r i o u s c o n t e n d e r t o h o l d i n g c o m p a n y j u r i s d i c t i o n s
T H E C Y P R U S H O L D I N G C O M P A N Y A s e r i o u s c o n t e n d e r t o h o l d i n g c o m p a n y j u r i s d i c t i o n s The contents of this publication are for information purposes
More informationMalta Country Profile
Malta Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Malta EU Member State Yes. Double Tax Treaties With: Albania Andorra Australia
More informationide: FRANCE Appendix A Countries with Double Taxation Agreement with France
Fiscal operational guide: FRANCE ide: FRANCE Appendix A Countries with Double Taxation Agreement with France Albania Algeria Argentina Armenia 2006 2006 From 1 March 1981 2002 1 1 1 All persons 1 Legal
More informationComperative DTTs of Pakistan
Comperative DTTs of Pakistan 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 S. No. COUNTRY CONTINENT Republic/Dem ocratic/kingdo m/sultanate P.E. BUSINESS PROFIT SHIPPING AIR TRANSPORT DIVIDEND INTEREST ROYALITIES
More informationLuxembourg Country Profile
Luxembourg Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Luxembourg EU Member State Yes Double Tax Treaties With: Albania (a) Andorra
More informationPoland Country Profile
Poland Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Poland EU Member State Yes Double Tax Treaties With: Albania Algeria Armenia
More informationWithholding Tax Handbook BELGIUM. Version 1.2 Last Updated: June 20, New York Hong Kong London Madrid Milan Sydney
Withholding Tax Handbook BELGIUM Version 1.2 Last Updated: June 20, 2014 Globe Tax Services Incorporated 90 Broad Street, New York, NY, USA 10004 Tel +1 212 747 9100 Fax +1 212 747 0029 Info@GlobeTax.com
More informationCyprus Country Profile
Cyprus Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Cyprus EU Member State Yes Double Tax Treaties With: Armenia Austria Bahrain
More informationDenmark Country Profile
Denmark Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Denmark EU Member State Double Tax Treaties With: Argentina Armenia Australia
More informationCyprus Country Profile
Cyprus Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Cyprus EU Member State Yes Double Tax Treaties With: Armenia Austria Bahrain
More informationOther Tax Rates. Non-Resident Withholding Tax Rates for Treaty Countries 1
Other Tax Rates Non-Resident Withholding Tax Rates for Treaty Countries 1 Country 2 Interest 3 Dividends 4 Royalties 5 Annuities 6 Pensions/ Algeria 15% 15% 0/15% 15/25% Argentina 7 12.5 10/15 3/5/10/15
More informationDouble tax considerations on certain personal retirement scheme benefits
www.pwc.com/mt The elimination of double taxation on benefits paid out of certain Maltese personal retirement schemes February 2016 Double tax considerations on certain personal retirement scheme benefits
More informationCyprus Double Tax Treaties
Seize the advantage of our expertise Fact Sheet This publication should be used as an initial source of general information only. It is not intended to give a definitive statement of the law. For the specific
More informationORD ISIN: DE / CINS CUSIP: D (ADR: / US )
The German Tax Agency (the BZSt) offers an electronic tax relief program (the DTV) designed to facilitate and accelerate German tax reclaims on equities by financial institutions. Acupay provides custodian
More informationWithholding Tax Rate under DTAA
Withholding Tax Rate under DTAA Country Albania 10% 10% 10% 10% Armenia 10% Australia 15% 15% 10%/15% [Note 2] 10%/15% [Note 2] Austria 10% Bangladesh Belarus a) 10% (if at least 10% of recipient company);
More informationGerry Weber International AG
The German Tax Agency (the BZSt) offers an electronic tax relief program (the DTV) designed to facilitate and accelerate German tax reclaims on equities by financial institutions. Acupay provides custodian
More informationDenmark Country Profile
Denmark Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Denmark EU Member State Double Tax With: Treaties Argentina Armenia Australia
More informationSweden Country Profile
Sweden Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Sweden EU Member State Double Tax Treaties With: Albania Armenia Argentina Azerbaijan
More informationT H E C Y P R U S F I N A N C E C O M P A N Y
T H E C Y P R U S F I N A N C E C O M P A N Y The contents of this publication are for information purposes only and can not be construed as providing any advice on matters including, but not restricted
More informationIreland Country Profile
Ireland Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Ireland EU Member State Yes Double Tax Treaties With: Albania Armenia Australia
More informationWithholding tax rates 2016 as per Finance Act 2016
Withholding tax rates 2016 as per Finance Act 2016 Sr No Country Dividend Interest Royalty Fee for Technical (not being covered under Section 115-O) Services 1 Albania 10% 10% 10% 10% 2 Armenia 10% 10%
More informationSerbia Country Profile
Serbia Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Serbia EU Member State Double Tax Treaties With: Albania Austria Azerbaijan Belarus
More informationNon-resident withholding tax rates for treaty countries 1
Non-resident withholding tax rates for treaty countries 1 Country 2 Interest 3 Dividends 4 Royalties 5 Annuities 6 Pensions/ Algeria 15% 15% 0/15% 15/25% Argentina 7 12.5 10/15 3/5/10/15 15/25 Armenia
More informationPaid from Cyprus Divident (1) % Interest (1) %
Tax treaties withholding tax tables The following tables give a summary of the withholding taxes provided by the double tax treaties entered into by Cyprus. Paid from Cyprus Divident Interest Royalties
More informationInvesting In and Through Singapore
Investing In and Through Singapore Shanker Iyer 17 May 2012 Contents Benefits of Singapore Setting Up and Ongoing Requirements Territorial Tax System Taxation of Passive Income and Other income Tax Incentives
More informationAlbania 10% 10%[Note1] 10% 10% Armenia 10% 10% [Note1] 10% 10% Austria 10% 10% [Note1] 10% 10%
Country Dividend (not being covered under Section 115-O) Withholding tax rates Interest Royalty Fee for Technical Services Albania 10% 10%[Note1] 10% 10% Armenia 10% Australia 15% 15% 10%/15% 10%/15% Austria
More information(of 19 March 2013) Valid from 1 January A. Taxpayers
Leaflet. 29/460 of the Cantonal Tax Office on withholding taxes applicable to pension benefits under private law for persons without domicile or residence in Switzerland (of 19 March 2013) Valid from 1
More informationDutch tax treaty overview Q3, 2012
Dutch tax treaty overview Q3, 2012 Hendrik van Duijn DTS Duijn's Tax Solutions Zuidplein 36 (WTC Tower H) 1077 XV Amsterdam The Netherlands T +31 888 387 669 T +31 888 DTS NOW F +31 88 8 387 601 duijn@duijntax.com
More informationSlovenia Country Profile
Slovenia Country Profile EU Tax Centre July 2015 Key tax factors for efficient cross-border business and investment involving Slovenia EU Member State Double Tax Treaties With: Albania Armenia Austria
More informationCyprus Country Profile
Cyprus Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Cyprus EU Member State Yes Double Tax With: Treaties Armenia Austria Bahrain
More informationTable of Contents. 1 created by
Table of Contents Overview... 2 Exemption Application Instructions for U.S. Tax Residents Living in the U.S.... 3 Exemption Application Instructions for Tax Residents of European Union Member States (other
More informationArgentina Bahamas Barbados Bermuda Bolivia Brazil British Virgin Islands Canada Cayman Islands Chile
Americas Argentina (Banking and finance; Capital markets: Debt; Capital markets: Equity; M&A; Project Bahamas (Financial and corporate) Barbados (Financial and corporate) Bermuda (Financial and corporate)
More informationMalta s Double Tax Treaties
Malta s Double Tax Treaties November 216 In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax
More informationINTERNATIONAL JOURNAL OF RESEARCH AND ANALYSIS VOLUME 5 ISSUE 2 ISSN
CRITICAL ANALYSIS ON DOUBLE TAXATION AVOIDANCE AGREEMENT **AASTHA SUMAN & HIMANSHU SHUKLA The DTAA, or Double countries) so that taxpayers can avoid paying double taxes on their income earned from the
More informationUkraine. WTS Global Country TP Guide Last Update: December Legal Basis
Ukraine WTS Global Country TP Guide Last Update: December 2017 1. Legal Basis Is there a legal requirement to prepare TP documentation? Since when does a TP documentation requirement exist in your country?
More informationCountries with Double Taxation Agreements with the UK rates of withholding tax for the year ended 5 April 2012
Countries with Double Taxation Agreements with the UK rates of withholding tax for the year ended 5 April 2012 This table shows the maximum rates of tax those countries with a Double Taxation Agreement
More informationTax Card KPMG in Bulgaria. kpmg.com/bg
Tax Card 2017 KPMG in Bulgaria kpmg.com/bg CORPORATE TAX Corporate income tax (CIT) is due on the accounting profit after adjustments for tax purposes. The applicable tax rate for the year 2017 is 10%.
More informationCross-Border Tax Regimes. Steven Sieker Partner, Baker McKenzie 28 June 2018
Cross-Border Tax Regimes Steven Sieker Partner, Baker McKenzie 28 June 2018 Taxation in the Cross-Border Context Payer service recipient / borrower / IP licensee / employer payments for services rendered
More informationTRENDS AND MARKERS Signatories to the United Nations Convention against Transnational Organised Crime
A F R I C A WA T C H TRENDS AND MARKERS Signatories to the United Nations Convention against Transnational Organised Crime Afghanistan Albania Algeria Andorra Angola Antigua and Barbuda Argentina Armenia
More informationEQUITY REPORTING & WITHHOLDING. Updated May 2016
EQUITY REPORTING & WITHHOLDING Updated May 2016 When you exercise stock options or have RSUs lapse, there may be tax implications in any country in which you worked for P&G during the period from the
More informationINVESTMENT IN TURKEY*
INVESTMENT IN TURKEY* Zeki Gündüz 25 April 2006 www.pwc.com/tr www.vergiportali.com/english *connectedthinking PwC Table of Contents 1 2 3 4 5 6 7 8 9 10 Annex Turkey and EU Incorporation of Companies
More informationa closer look GLOBAL TAX WEEKLY ISSUE 249 AUGUST 17, 2017
GLOBAL TAX WEEKLY a closer look ISSUE 249 AUGUST 17, 2017 SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL
More informationDefinition of international double taxation
Definition of international double taxation Juridical double taxation: imposition of comparable taxes in two (or more) States on the same taxpayer in respect of the same subject matter and for identical
More informationSpain Country Profile
Spain Country Profile EU Tax Centre July 2016 Key tax factors for efficient cross-border business and investment involving Spain EU Member State Double Tax Treaties With: Albania Algeria Andorra Argentina
More informationCross Border Investments (inc. M&A) through Singapore
Cross Border Investments (inc. M&A) through Singapore Shanker Iyer 22 August 2015 SINGAPORE HONGKONG 20 YEARS IN PRACTICE AGENDA Non-Tax Issues Tax Issues SINGAPORE HONGKONG 20 YEARS IN PRACTICE NON-TAX
More informationAPA & MAP COUNTRY GUIDE 2017 CANADA
APA & MAP COUNTRY GUIDE 2017 CANADA Managing uncertainty in the new tax environment CANADA KEY FEATURES Competent authority APA provisions/ guidance Types of APAs available APA acceptance criteria Key
More informationMalta s Double Tax Treaties
Malta s Double Treaties February 216 In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax treaties
More informationFOREWORD. Services provided by member firms include:
2016/17 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
More informationFOREWORD. Egypt. Services provided by member firms include:
2015/16 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
More informationBULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - APRIL 2017 (PRELIMINARY DATA)
BULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - APRIL 2017 (PRELIMINARY DATA) In the period January - April 2017 Bulgarian exports to the EU increased by 8.6% 2016 and amounted to 10 418.6 Million BGN
More informationBULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - MAY 2017 (PRELIMINARY DATA)
BULGARIAN TRADE WITH EU IN THE PERIOD JANUARY - MAY 2017 (PRELIMINARY DATA) In the period January - May 2017 Bulgarian exports to the EU increased by 10.8% 2016 and added up to 13 283.0 Million BGN (Annex,
More informationGreece Country Profile
Greece Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Greece EU Member State Double Tax Treaties With: Albania Armenia Austria Azerbaijan
More informationCYPRUS: Gateway to Europe and the World The continuing efficient use of Cyprus in international structuring
CYPRUS: Gateway to Europe and the World The continuing efficient use of Cyprus in international structuring Sissy Zhang, BSc, MSc, ACCA General Manager Totalserve Management (Beijing) Ltd sissy.zhang@totalserve.eu
More informationThe UAE as a Structuring Hub
The UAE as a Structuring Hub MATTHIEU DAGUERRE TTN NICE 25 SEPTEMBER 2015 www.m-hq.com PART I PART II PART III HIGH LEVEL OVERVIEW WHICH VEHICLE FOR WHICH PURPOSE A COUPLE OF BESTSELLERS UNDER THE SPOTLIGHT
More informationPortugal Country Profile
Portugal Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Portugal EU Member State Double Tax Treaties Yes With: Algeria Andorra (a)
More informationFOREWORD. Estonia. Services provided by member firms include:
2016/17 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
More informationSection 872. Gross Income. Rev. Rul
Section 872. Gross Income (Also sections 883, 894.) 26 CFR 1.872 2: Exclusions from gross income of nonresident alien individuals. (Also 26 CFR 1.883 1.) This revenue ruling updates the list of countries
More informationCyprus Tax Facts 2017 Tax
Cyprus Tax Facts 2017 Tax Deloitte in Cyprus 1 Income Tax - Individuals 2 Income Tax - Companies 8 Profits from Intellectual Property 16 Special Contribution for Defence 18 Profits from Shipping Activities
More informationSpain France. England Netherlands. Wales Ukraine. Republic of Ireland Czech Republic. Romania Albania. Serbia Israel. FYR Macedonia Latvia
Germany Belgium Portugal Spain France Switzerland Italy England Netherlands Iceland Poland Croatia Slovakia Russia Austria Wales Ukraine Sweden Bosnia-Herzegovina Republic of Ireland Czech Republic Turkey
More informationwts study Global WTS PE Study A high-level overview of most discussed PE issues in EU, OECD and BRICS countries
wts study Global WTS PE Study A high-level overview of most discussed PE issues in EU, OECD and BRICS countries Table of Contents Preface 3 Conclusions at a glance 4 Summary from the survey 5 Detailed
More informationScale of Assessment of Members' Contributions for 2008
General Conference GC(51)/21 Date: 28 August 2007 General Distribution Original: English Fifty-first regular session Item 13 of the provisional agenda (GC(51)/1) Scale of Assessment of s' Contributions
More informationThe Global Tax Reset 2017 Audit Committee Symposium
The Global Tax Reset Copyright 2017 Deloitte Development LLC. All rights reserved. 2017 Audit Committee Symposium Anticipate. Navigate. Focus. 1 The Global Tax Reset General context Multinational companies
More information