[CORPORATION TAX BRIEFING] ICPAC SEMINAR 15 th & 16 th January 2015
|
|
- Gertrude Payne
- 5 years ago
- Views:
Transcription
1 2015 ICPAC SEMINAR 15 th & 16 th January 2015 [CORPORATION TAX BRIEFING] The contents of the notes to follow constitute a general overview of the corporate tax system in Cyprus.
2 Corporation tax Introduction A company is not considered as a Cyprus tax resident company just through incorporation. A company is subject to Cyprus corporation tax (at the flat rate of 12.5%) irrespective of its country of incorporation, if such company proves that it is effectively managed and controlled in Cyprus. There are no detailed guidelines (nor a proper definition) of what are the management and control requirements. It is however used as basic principles that at least the following need to be adhered to: 1. The majority of the Board of Directors are tax residents in Cyprus 2. Strategic (and preferably also administrative, day to day) decisions are performed in Cyprus This is typically achieved through proving that: 2.1 Resolutions prepared and signed in Cyprus 2.2 Board of Director Meetings performed in Cyprus 2.3 Accounting, hard copies, contracts are maintained/performed/kept in Cyprus 2.4 Bank accounts are operated in Cyprus (this does not mean only through Cyprus banks but that the operation of foreign banks is handled through Cyprus) Note however: 2.5 Currently many Companies are registered in Cyprus and maintain nominee shareholders, directors, secretaries and operate through the address of some fiduciary office 2.6 In the strict essence this is not entirely transparent 2.7 Emphasis must be given on creating/establishing true substance of operations in Cyprus (discussion in the seminar on how to achieve such) 2.8 From a Cyprus tax perspective it is easy to prove effective management control. Structures in Cyprus are however continuously challenged from tax authorities abroad (as the objective of setting up a Cyprus company is clear)
3 Basis of corporation tax Cyprus tax resident companies are taxed on their worldwide income, subject to allowing a tax credit for any tax suffered in a foreign location on income which is also subject to tax in Cyprus. Non - resident companies are taxed in Cyprus only on: 1. Profits attributable to a permanent establishment in Cyprus 2. Rental income derived from immovable property situated in Cyprus 3. Profit from the sale of goodwill of a business exercised/existing in Cyprus Income that is subject to corporation tax Appendix 1 to these notes provides a detailed analysis, together with explanatory notes on: 1. How profits of a Cyprus tax resident company are adjusted for corporation tax purposes (IR4) 2. What reliefs are available 3. Details of how losses can be utilised (either at a Company or Group level) 4. Double tax relief Temporary and final settlement of corporation tax Every Cyprus tax resident company needs to prepay its corporation tax in 2 instalments. For the 2013 tax year, a company prepays its corporation tax through the temporary tax (provisional) system in 2 equal instalments on the 31 st June 2013 and the 31 st December The balance of any tax due (or refund) is due by the 1 st August 2014 (next year). Special attention is required when addressing the issue of temporary tax. In reality you will consider the past results of the client in conjunction with the current (2013) interim results at the date of submitting the temporary tax. A client can revise its submitted temporary tax before the year-end (i.e. before the 31 st December 2013). Therefore it is recommended that the initial form submitted is as prudent (As low as possible) and that the results are investigated by the tax advisor again before the year end. The tax office imposes a 10% penalty if the temporary tax paid is less than 75% of the actual tax burden of the company. See examples in class on application of all the above that include: 1. Imposition of 10% penalty and interest 2. Revision of temporary tax before the year end
4 Advanced issues relating to corporation tax Issue 1 Permanent establishment rules Understand that a permanent establishment is not a separate legal entity (i.e. subsidiary) but part of the company in question. As such, the results of the permanent establishment appear in the stand alone financial statements of the Company carrying out the permanent establishment. A permanent establishment set abroad by a Cyprus company is taxed in Cyprus ONLY if the permanent establishment: 1. Pays tax substantially lower in its country of establishment (less than 6%) AND 2. It engages in investment activities that are in excess of 50% of its overall activities If the PE satisfies both conditions mentioned above then the results of the PE are fully taxable in Cyprus. This means that the Cyprus company carrying out the PE abroad will be taxed on the PE profits and will be granted a tax allowance in case of a loss, If at least one of the two conditions stated above are not met, then the PE is taxed abroad. This effectively means that since the results of the PE are included in the financial statements of the Cyprus company then: 1. In the case of PE profits you will always DEDUCT these profits from your tax computation 2. In the case of PE losses note the following: Since a profit is deducted, similarly a loss should be added back. The Cyprus tax office wants to encourage Cyprus companies opening and operating legal PE abroad and as such provides the following incentive when a PE makes a loss: Do not add back the losses of a PE until the PE makes a profit, in which year the losses would be recaptured. Practically this means: No adjustment will be made in the financial statements of the Cyprus company when the PE makes a loss (say loss of Euro 12 m).
5 When the PE in the future makes a profit then: 2.1 If the profit is say Euro 15m, you will deduct the profits of Euro 15m and at the same time add back the losses of Euro 12m (recapture) 2.2 If the profits are say Euro 10m, again you will deduct the profits of Euro 10m, but you will only recapture previous losses up to the amount of the profit (i.e you will add back losses of Euro 10m). This means that in the future, the company will have to recapture a further Euro 2m of PE losses when the PE makes a profit. See further examples in class to fully understand the taxation of PE abroad. According to the guidelines issued by the OECD, a permanent establishment is: 1. A fixed place of business through which a part of a company is carried on 2. Specifically, the following are considered as permanent establishments: 2.1 A place of management 2.2 A branch 2.3 A office 2.4 A factory 2.5 A place of extracting natural resources (i.e. mine) 2.6 A building site whereby services/supervision offered lasts more than 3 months 3. The following are not considered as permanent establishments: 3.1 Use of storage facilities 3.2 Use of facilities for purchasing orders 3.3 Use of facilities for collecting information 3.4 Use of a broker/commission agent in the ordinary course of business Issue 2 The new legislation on taxation of intellectual property As from the 1 st January 2012, new rules govern the taxation of Cyprus tax resident companies dealing with intellectual property. The new rules provide increased incentives for the set up of Companies in Cyprus with rights to intellectual property, as: 1. Wear and tear of 20% is provided to the cost of the intellectual property 2. An 80% allowance is provided on the profits subject to tax 3. Hence the effective rate of tax for such companies cannot in any case exceed 2.5%
6 Intellectual property covers the following: 1. Scientific work 2. Literary work 3. Musical work 4. Artistic work 5. Movies 6. Databases 7. Recordings 8. Broadcasting 9. Publications 10. Patents as governed and defined by the Patents Law 11. Trademarks as governed and defined by the Trademarks Law How intellectual property is taxed The new tax laws apply to intellectual property purchased or developed (development meeting the definition of international financial reporting standards) after or on the 1 st January For tax purposes, the profits subject to corporation tax are derived as follows: Income from intellectual property (say royalties) 20m Less: Research expenses (if any) Nil Amortisation of the intangible asset * (2m) Interest expenses (0.2m) Normal allowable expense (0.5m) Profit before granted deduction 17.3m Less 80% special deduction granted* (13.84m) Profit subject to corporation tax 3.46m Corporation tax at 12.5% 0.43m (Effective tax rate in this illustration being 0.43m/20m = 2.15% ====== Notes to the above illustration 1. The tax office allows a wear and tear allowance (to compensate for amortization) at 20%. In the above illustration, it is assumed that the cost of the intangible asset was Euro 10m. 2. An 80% deduction is granted by the Cyprus tax office on resulting profits (as illustrated above).
7 In case of sale of intellectual property The profits from the sale of the intellectual property are also given an 80% allowance before calculating corporation tax at 12.5%. Issue 3 Capital allowances Capital allowances are granted in two modes by the Cyprus tax office: 1. An annual wear and tear allowance (in replacement of depreciation) 2. A balancing statement when an asset is sold (in replacement of an accounting disposal). Wear and tear guidelines 1. Wear and tear follow the period of the financial statements. If the financial statements are for 12 months, then wear and tear is granted fully. If the financial statements are for say 7 months, then wear and tear will be granted as a fraction (7/12). 2. Full wear and tear in the year of acquiring the asset. Zero wear and tear in the year of disposing an asset. 3. Wear and tear is granted on assets that are used for the generation of taxable income of the Cyprus tax resident company. Hence the following assets do not qualify for wear and tear purposes: 3.1 Privately used assets 3.2 Saloon cars 4. Wear and tear is granted on a straight line method. 5. Fixed rates of wear and tear exist (see appendix). Balancing statement guidelines Accounting wise, when an asset is disposed, the accountant will calculate an accounting profit being proceeds less the carrying value of the asset (carrying value being cost less accumulated depreciation). Since the accountants calculation includes depreciation, the end result whether a profit or a loss is not recognised by the tax office. Hence: 1. An accounting profit on the sale of an asset is deducted from our tax computation 2. An accounting loss is similarly added back In replacement of the above, the tax office demand the preparation of a balancing statement, whereby the taxable profit or loss is: Proceeds less tax written down value of the asset (TWDV) Whereby TWDV is the cost less accumulated wear and tear of the asset
8 The above calculation (Balancing statement) can give rise to either: 1. Balancing charge (profit) which is added in your tax computation 2. Balancing allowance (loss) which is deducted from your tax computation Note that in case of a Balancing Charge, the taxable amount is restricted to the lower of: 1. Balancing charge or 2. Accumulated wear and tear claimed You will not prepare a Balancing Statement for assets on which wear and tear allowances have not been claimed. Some advanced issues relating to capital allowances are: 1. Second hand buildings If a building is purchased has been previously used (second hand), then the cost eligible for wear and tear is the lower of: 1.1 Price paid to the seller or 1.2 Original cost of construction of the seller Both after deducting the cost of the land portion See illustrations in class for preparing a balancing statement on a second hand building. 2. Electing the replacement model A company disposing an item of PPE and on which a balancing charge has been created, may elect (written confirmation is required by the tax office) to apply the replacement model, that details the following: 2.1 The balancing charge is not taxed in the year of the disposal 2.2 Provided a replacement asset is bought (in replacement to the original disposed), then the balancing charge is credited against the cost of the replacement asset 2.3 This means that the replacement asset will have a lower cost for capital allowance purposes 2.4 In case where the cost of the replacement asset is lower than the balancing charge, then the excess of the balancing charge is taxable immediately, and the cost of the replacement is deemed to be zero for capital allowance purposes
Profit before tax (as per audited financial statements)
Appendix 1 Basic tax computation for corporation tax purposes Profit before tax (as per audited financial statements) Notes Euro Add: Add: Non allowable expenses Depreciation of property, plant and equipment
More informationInformation Sheet No. 66. The New Intellectual Property (IP) Tax Regime in Cyprus
Information Sheet No. 66 The New Intellectual Property (IP) Tax Regime in Cyprus Introduction On 14 October 2016, the House of Representatives passed amendments to the Income Tax Law in order to align
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 informationFundamentals Level Skills Module, Paper F6 (CYP)
Answers Fundamentals Level Skills Module, Paper F6 (CYP) Taxation (Cyprus) December 205 Answers and Marking Scheme Section A C Accounting profit 5,000 Less: Corporation tax (5,000) 00,000 Deemed distribution
More informationStructures. Including Cyprus
Structures Including Cyprus Structures Including Cyprus Cyprus is widely known as one of the most beneficial holding company jurisdictions, hence, the Cyprus holding company has become a major vehicle
More informationTaxation of cross-border mergers and acquisitions
Taxation of cross-border mergers and acquisitions Cyprus kpmg.com/tax KPMG International Cyprus Introduction The Income Tax Law No.118 (I) 2002 introduced major reforms of Cyprus s tax system at the time
More informationFundamentals Level Skills Module, Paper F6 (CYP)
Answers Fundamentals Level Skills Module, Paper F6 (CYP) Taxation (Cyprus) Alexis and Maria Pambos June 203 Answers and Marking Scheme Marks Capital/(net worth) statement for the period January 2007 to
More informationChapter 11 Tax System
Chapter 11 Tax System www.pwc.com/mt/doingbusiness Doing Business in Malta Principal taxes The principal taxes under Maltese law are: Income tax, which includes tax on income and on capital gains of individuals,
More informationCyprus United States of America Double Tax Treaty
Cyprus United States of America Double Tax Treaty AGREEMENT OF 19 TH MARCH, 1984 This is the Convention between the Government of the United States of America and the Government of the Republic of Cyprus
More informationDoing business in Denmark 2019
Moore Stephens Danmark presents Doing business in Denmark 2019 www.moorestephens.dk PRECISE. PROVEN. PERFORMANCE. Introduction The purpose of this publication is to give an introduction to those considering
More informationFundamental Level Skills Module, Paper F6 (CYP)
Answers Fundamental Level Skills Module, Paper F6 (CYP) Taxation (Cyprus) Mr Tsangaris December 2008 Answers and Marking Scheme Marks (a) Capital (net worth) statement January 2002 3 December 2007 Assets
More informationRent Payments vs. Installment Purchases
Rent Payments vs. Installment Purchases If a business rents anything necessary for the business, such as an office, a copier, machinery, etc., 100% of the rent can usually be deducted as an ordinary business
More informationTax Briefing No 09. This content is more than 5 years old. Where still relevant it has been incorporated. into a Tax and Duty Manual
Revenue Commissioners Tax Briefing No 09 2010 Intangible Assets Scheme under Section 291A Taxes Consolidation Act 1997 1. Introduction Section 43 of the Finance Act 2010 makes a number of amendments to
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 informationINTRODUCTION. Situations should be viewed separately based on specific facts of each scenario.
TAX FACTS 2018 CONTENTS INTRODUCTION... 3 PERSONAL INCOME TAX... 4 CORPORATION TAX... 8 SOCIAL INSURANCE... 12 SPECIAL CONTRIBUTION FOR DEFENCE... 13 INTELLECTUAL PROPERTY... 16 VALUE ADDED TAX... 18 CAPITAL
More informationFundamentals Level Skills Module, Paper F6 (CYP) Capital/(net worth) statement 1 January 31 December
Answers Fundamentals Level Skills Module, Paper F6 (CYP) Taxation (Cyprus) Mr Costantinos June 202 Answers and Marking Scheme Marks (a) Capital/(net worth) statement January 3 December 2006 20 Assets Bank
More informationIMPORTANT ECONOMIC INCENTIVES Article by Liam Grimes, Director of Tax, KPMG, Moderator Professional 2 Advanced Taxation.
IMPORTANT ECONOMIC INCENTIVES Article by Liam Grimes, Director of Tax, KPMG, Moderator Professional 2 Advanced Taxation. The changes introduced in Finance (No. 2) Act 2008 to research and development tax
More informationFundamentals Level Skills Module, Paper F6 (MLA)
Answers Fundamentals Level Skills Module, Paper F6 (MLA) Taxation (Malta) Nicholas and Janet December 203 Answers and Marking Scheme Marks (a) Nicholas and Janet have moved to Malta with a view to taking
More informationTAX CONSEQUENCES FOR CANADIANS DOING BUSINESS IN THE U.S.
TAX CONSEQUENCES FOR CANADIANS DOING BUSINESS IN THE U.S. Has your Canadian business expanded into the U.S.? Do you have dealings with U.S. customers? If so, have you considered the U.S. tax implications?
More informationTaiwan. Country M&A Team Country Leader ~ Steven Go Legal Service: Eric Chao-An Tsai Ross Yang Tax Service: Tony Lin Elaine Hsieh
Taiwan Country M&A Team Country Leader ~ Steven Go Legal Service: Eric Chao-An Tsai Ross Yang Tax Service: Tony Lin Elaine Hsieh Mergers & Acquisitions Asian Taxation Guide 2008 Taiwan March 2008 PricewaterhouseCoopers
More informationFundamentals Level Skills Module, Paper F6 (CYP) Capital (net worth) statement 1 January 31 December
Answers Fundamentals Level Skills Module, Paper F6 (CYP) Taxation (Cyprus) Mr Ourin December 00 Answers and Marking Scheme Marks (a) (b) Capital (net worth) statement January 3 December 004 009 Assets
More information2014 CYPRUS TAX BOOK M.P. MULTI-COUNT SERVICES LTD CERTIFIED PUBLIC ACCOUNTANTS
2014 CYPRUS TAX BOOK M.P. MULTI-COUNT SERVICES LTD CERTIFIED PUBLIC ACCOUNTANTS The Cyprus tax book is intended to provide a general guide only to the subject matter and is based on taxation law as at
More informationTax Seminar 2015 Know the rules, know your way ahead. December 15, 2015
Tax Seminar 2015 Know the rules, know your way ahead December 15, 2015 Agenda Corporate Tax Withholding Tax Practical Issues Overview of the TAS Questions and answers 2 2015 Deloitte & Touche (M.E.) Overview
More informationInternational Accounting Standard 12 Income Taxes. Objective. Scope. Definitions IAS 12
International Accounting Standard 12 Income Taxes Objective The objective of this Standard is to prescribe the accounting treatment for income taxes. The principal issue in accounting for income taxes
More informationPAPER 2.03 CYPRUS OPTION
THE ADVANCED DIPLOMA IN INTERNATIONAL TAXATION June 2015 PAPER 2.03 CYPRUS OPTION ADVANCED INTERNATIONAL TAXATION (JURISDICTION) Suggested Solutions Question 1 Part 1 Both Giovanni and Lena will be taxed
More informationCyprus. Tax Facts 2013
Cyprus Tax Facts 2013 1 2 Cyprus Tax Facts 2013 Contents BUSINESS TAXATION Income Tax 2-5 SpecIal contribution To The Defence fund 6-7 capital GaInS Tax 8 Immovable property Tax 9 land registry fees 9
More informationIRELAND GLOBAL GUIDE TO M&A TAX: 2017 EDITION
IRELAND 1 IRELAND INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? A reduced rate of capital gains tax ( CGT ) of 20%
More informationCyprus Tax News Amendments to Cyprus s IP regime
Cyprus Tax & Legal Services 27 October 2016 Issue 14/2016 Cyprus Tax News Amendments to Cyprus s IP regime INTRODUCTION On 14 October 2016, the House of Representatives enacted into law significant amendments
More informationAdvanced Financial Accounting and Reporting (AFAR)
SET A SEPTEMBER 2015 SUGGESTED SOLUTION QUESTION 1 a) Labian Bhd Consolidated Statement of Profit or Loss and Other Comprehensive Income for the year ended 30 June 2015 000 Revenue (176,400 + 105,840)
More informationMarel hf. Consolidated Interim Financial Statements 31 March 2007
Marel hf Consolidated Interim Financial Statements 31 March 2007 Index Pages The Board of Directors' and the CEO's Report... 2 Financial Ratios... 3 Consolidated Income Statement... 4 Consolidated Balance
More informationDoing Business in Denmark
Doing Business in Denmark 2018 Introduction The purpose of this publication is to give an introduction to those considering conducting business in Denmark, either by establishing a company or a branch
More informationTAIWAN. Country M&A Team Country Leader ~ Steven Go Elliot Liao Eric Chao-An Tsai Tony Lim Violet Lo. 263 PricewaterhouseCoopers
263 PricewaterhouseCoopers TAIWAN Country M&A Team Country Leader ~ Steven Go Elliot Liao Eric Chao-An Tsai Tony Lim Violet Lo 264 PricewaterhouseCoopers Name Designation Office Tel Email Steven Go Partner
More informationTax treatment of Rental Income
Tax treatment of Rental Income Rental income earned from immovable property situated in Cyprus or abroad, received by a Cyprus tax resident person (company or individual), is subject to the following two
More informationDOING BUSINESS IN CYPRUS: CYPRUS COMPANY & TRUST FORMATION
DOING BUSINESS IN CYPRUS: CYPRUS COMPANY & TRUST FORMATION 1 PREFACE G Vassiliou law office has prepared this outline in order to assist any individuals or businesses that might be considering Doing business
More informationSection A. 1 D All other statements are FALSE about tax evasion 2 B 21,400 (20, ,000) 3 A 49,050 (50, ) 4 B 31,250
Answers Applied Skills, TX CYP Taxation Cyprus (TX CYP) December 208 Answers and Marking Scheme Section A D All other statements are FALSE about tax evasion 2 B 2,400 (20,400 +,000) 3 A 49,050 (50,000
More informationGKN HOLDINGS PLC Registered Number: ANNUAL REPORT 31 DECEMBER 2012
GKN HOLDINGS PLC Registered Number: 66549 ANNUAL REPORT 31 DECEMBER 2012 Directors Report Directors: Mr N M Stein Mrs J M Felton Mr W C Seeger 1. The Directors present their report together with the audited
More informationMODULE 2.03 CYPRUS OPTION
THE ADVANCED DIPLOMA IN INTERNATIONAL TAATION June 2018 MODULE 2.03 CYPRUS OPTION SUGGESTED SOLUTIONS PART A Question 1 Part 1 Dr Giovanni did not spent more than 183 days in Cyprus during 2017 and so
More informationFundamentals Level Skills Module, Paper F6 (CYP)
Answers Fundamentals Level Skills Module, Paper F6 (CYP) Taxation (Cyprus) Section B June 206 Answers and Marking Scheme Marks Charalambos (a) Value added tax (VAT) return for the quarter ended 30 September
More informationIncome Taxes. Indian Accounting Standard (Ind AS) 12. Objective
Indian Accounting Standard (Ind AS) 12 Income Taxes (This Indian Accounting Standard includes paragraphs set in bold type and plain type, which have equal authority. Paragraphs in bold type indicate the
More informationAccounting policies extracted from the 2016 annual consolidated financial statements
Steinhoff International Holdings N.V. (Steinhoff N.V.) is a Netherlands registered company with tax residency in South Africa. The consolidated annual financial statements of Steinhoff N.V. for the period
More informationFINANCIAL REPORTING IAS 12 DEFERRED TAX
FINANCIAL REPORTING IAS 12 DEFERRED TAX Presentation by: CPA Boniface L Souza, ACIM, CFIP Friday, 2 nd November, 2018 Uphold public interest Agenda Introduction Objective of Deferred Taxation Recognition
More informationTEI School - Houston. Intangible Property ( IP ) - Basics in IP Planning. May 3, 2017
TEI School - Houston Intangible Property ( IP ) - Basics in IP Planning May 3, 2017 Disclaimer EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global
More informationAGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SOUTH AFRICA AND THE GOVERNMENT OF THE KINGDOM OF LESOTHO FOR THE AVOIDANCE OF DOUBLE TAXATION AND
AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF SOUTH AFRICA AND THE GOVERNMENT OF THE KINGDOM OF LESOTHO FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES
More informationCyprus - Iran. The gateway to Iranian business
Cyprus - Iran CYPRUS - IRAN CONTENT Introduction 3 Cyprus: Tax Benefits 4 New Treaty Cyprus - Iran 5 Cyprus Holding Company 6 Cyprus Holding Company in International 7 Investments Cyprus Back-to-Back Financing
More informationDesiring to further develop their economic relationship and to enhance their co-operation in tax matters,
CONVENTION BETWEEN JAPAN AND THE REPUBLIC OF SLOVENIA FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE Japan and the Republic of Slovenia,
More informationLAW OF MONGOLIA. CORPORATE INCOME TAX (Amended Law) CHAPTER ONE General Provisions
LAW OF MONGOLIA June 29.2006 State Palace, Ulaanbaatar CORPORATE INCOME TAX (Amended Law) CHAPTER ONE General Provisions Article 1. Purpose of the law 1.1. The purpose of this law is to regulate relations
More informationConvention between Canada and the Republic of Chile for the Avoidance of Double Taxation and the...
Page 1 of 11 Français Contact Us Help Search Canada site Home What's New Site Map Glossary HotLinks About Us FAQ Media Room Publications Legislation - Notices of Tax Treaty Developments - Status of Tax
More informationConsolidated Financial Statements
Gedeon Richter Consolidated Financial Statements 2013 Consolidated Financial Statements Table of Contents Consolidated Income Statement 6 Consolidated Statement of Comprehensive Income 6 Consolidated Balance
More informationLuxembourg Corporate Taxation
Introduction Corporate income is subject to corporate income tax, increased by a surcharge for the employment fund and a municipal business tax. Companies are also subject to net worth tax. Social security
More informationTax payable: 19,500 x 0% 0 0 8,500 x 20% 1,700 1,700 8,300/6,078 x 25% 2,075 1,520 5,033 x 30% 1,510 Income tax payable 5,285
Answers Professional Level Options Module, Paper P6 (CYP) Advanced Taxation (Cyprus) December 2016 Answers 1 C&A Design Services/C&A Design Services Ltd (a) Comparative calculations of the overall taxes
More informationSA/Mauritius DTA changes & challenges. Celia Becker 26 & 27 March 2015
SA/Mauritius DTA changes & challenges Celia Becker 26 & 27 March 2015 content background changes & challenges conclusion effective date questions and discussion background background current SA / Mauritius
More informationand Marking Scheme 40 Total equity and liabilities 1,056,966
Answers Diploma in International Financial Reporting December 203 Answers and Marking Scheme Marks Consolidated statement of financial position of Alpha at 30 September 203 ASSETS Non-current assets: Property,
More informationd o i n g b u s i n e s s i n d e n m a r k
d o i n g b u s i n e s s i n d e n m a r k 2 0 0 8 Kreston Denmark The constructive alternative: KRESTON DENMARK A national association of independent State Authorized Public Accountants We combine the
More informationIncome Taxes. International Accounting Standard 12 IAS 12. IFRS Foundation A625
International Accounting Standard 12 Income Taxes In April 2001 the International Accounting Standards Board (IASB) adopted IAS 12 Income Taxes, which had originally been issued by the International Accounting
More informationFilm Financing and Television Programming: A Taxation Guide
Film Financing and Television Now in its seventh edition, KPMG LLP s ( KPMG ) Film Financing and Television (the Guide ) is a fundamental resource for film and television producers, attorneys, tax executives,
More informationSSAP 12 STATEMENT OF STANDARD ACCOUNTING PRACTICE 12 INCOME TAXES
SSAP 12 STATEMENT OF STANDARD ACCOUNTING PRACTICE 12 INCOME TAXES (Issued August 2002) Contents Paragraphs OBJECTIVE SCOPE 1-4 DEFINITIONS 5-11 Tax Base 7-11 RECOGNITION OF CURRENT TAX LIABILITIES AND
More informationFederal Income Taxation Chapter 15 Capital Cost Recovery
Presentation: Federal Income Taxation Chapter 15 Capital Cost Recovery Professors Wells October 24, 2017 Antiques p.870 Richard L. Simon Simon acquired two Tourte bows for $30,000 and $21,000, respectively.
More informationTax Management International Forum
Tax Management International Forum Comparative Tax Law for the International Practitioner Reproduced with permission from Tax Management International Forum, 39 FORUM 38, 6/5/18. Copyright 2018 by The
More informationOur international networks. Turin Office. Milan Office. London Office
Turin Office P.za Carlo Emanuele II, 13 10123 Turin - Italy T +39 011.5611319 F +39 011.540586 Our international networks Milan Office Via Sant Orsola, 4 20123 Milano - Italia T +39 02.58307740 F +39 02.58302986
More informationThe Swiss Federal Council and the Government of the Hong Kong Special Administrative Region of the People s Republic of China,
AGREEMENT BETWEEN THE SWISS FEDERAL COUNCIL AND THE GOVERNMENT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION OF THE PEOPLE S REPUBLIC OF CHINA FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES
More informationIt is time that brings results.
It is time that brings results. Financial statements The dimensions of growth are measured over time. Time defines how high we grow, how broadly our branches spread, and how far our ideas will grow. We
More informationInternational Tax Malta Highlights 2018
International Tax Malta Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control No Accounting principles/financial statements IAS/IFRS/General Accounting Principles for Small and
More informationCharltons. Hong Kong. August Hong Kong And Russia Double Taxation Agreement Comes Into Force Introduction SOLICITORS
And Russia Double Taxation Agreement Comes Into Force Introduction The Russia - agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income ( Russia
More informationInternational Tax Malta Highlights 2019
International Tax Updated January 2019 Recent developments: For the latest tax developments relating to Malta, see Deloitte tax@hand. Investment basics: Currency Euro (EUR) Foreign exchange control No
More informationDoing Business in Denmark
This document describes some of the key commercial and taxation factors that are relevant on setting up a business in Denmark. Prepared by Addere Revision 2 Doing Business in Denmark Background Country
More informationCONVENTION BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE GOVERNMENT OF THE REPUBLIC OF CYPRUS
CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND AND THE GOVERNMENT OF THE REPUBLIC OF CYPRUS FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON
More informationThis version includes amendments resulting from IFRSs issued up to 31 December 2009.
International Accounting Standard 12 Income Taxes This version includes amendments resulting from IFRSs issued up to 31 December 2009. IAS 12 Income Taxes was issued by the International Accounting Standards
More informationGedeon Richter Consolidated Financial Statements 2014
Gedeon Richter Consolidated Financial Statements Consolidated Financial Statements Table of contents Consolidated Income Statement 6 Consolidated Statement of Comprehensive Income 6 Consolidated Balance
More informationABERTIS INFRAESTRUCTURAS, S.A. Financial Statements and Directors' Report for the year ended 31 December 2016
ABERTIS INFRAESTRUCTURAS, S.A. Financial Statements and Directors' Report for the year ended 31 December 2016 CONTENTS Balance sheets as at 31 December... 2 Statements of profit or loss... 4 Statements
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 information- (1.7) (6.6) Profit attributable to ordinary shareholders Earnings per share 5 Basic 2.3p 2.5p 10.6p Diluted 2.3p 2.5p 10.
Consolidated Profit and Loss Account For the 13 weeks ended 1st May 2005 Notes Revenue 2 196.4 200.3 776.7 Cost of sales (117.5) (119.9) (462.2) Gross profit 78.9 80.4 314.5 Total operating expenses (61.4)
More informationUK/NETHERLANDS DOUBLE TAXATION CONVENTION AND PROTOCOL SIGNED IN LONDON ON 26 SEPTEMBER 2008
UK/NETHERLANDS DOUBLE TAXATION CONVENTION AND PROTOCOL SIGNED IN LONDON ON 26 SEPTEMBER 2008 This Convention and Protocol have not yet entered into force. This will happen when both countries have completed
More informationD o i n g b u s i n e s s i n D e n m a r k
Kreston Denmark Doing business in denmark 2013 Introduction The purpose of this publication is to give an introduction to those considering conducting business in Denmark, either by establishing a company
More informationABERTIS INFRAESTRUCTURAS, S.A. Financial Statements and Directors' Report for the year ended 31 December 2017 CONTENTS Balance sheets as at 31 December... 2 Statements of profit or loss... 4 Statements
More informationTAXATION OF KNOWLEDGE-BASED CAPITAL: SOME ADDITIONAL ISSUES FOR POLICYMAKERS CONSIDERATION 1. By Alessandro Modica 2 and Thomas Neubig 3
TAXATION OF KNOWLEDGE-BASED CAPITAL: SOME ADDITIONAL ISSUES FOR POLICYMAKERS CONSIDERATION 1 By Alessandro Modica 2 and Thomas Neubig 3 Presented at the National Tax Association Annual Conference, November
More informationChapter 15 p.869 Capital Cost Recovery
Chapter 15 p.869 Capital Cost Recovery Code 167(a) allows a depreciation deduction for a reasonable allowance for the exhaustion, wear and tear (including for obsolescence) of property: (1) used in a trade
More informationTAXATION ISSUES TO CONSIDER WHEN OPERATING OVERSEAS
WA DIVISION 14 July 2005 City West Function Centre, West Perth TAXATION ISSUES TO CONSIDER WHEN OPERATING OVERSEAS Written by/presented by: Marc Worley Director KD Johns & Co. Taxation Institute of Australia
More informationProfessional Level Options Module, Paper P6 (CYP) 1 Capoda Ltd
Answers Professional Level Options Module, Paper P6 (CYP) Advanced Taxation (Cyprus) June 2013 Answers 1 Capoda Ltd (a) To: Laurence, MD Capoda Ltd From: Nicos, Tax Advisor Date: 16 January 2012 Re: Presentation
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 informationFundamentals Level Skills Module, Paper F6 (MLA)
Answers Fundamentals Level Skills Module, Paper F6 (MLA) Taxation (Malta) Section B December 2017 Answers and Marking Scheme 1 (a) Happy Shoppers Limited (HSL) The transaction constitutes an importation
More informationOAO Scientific Production Corporation Irkut
Consolidated Financial Statements for the year ended 31 December 2011 Consolidated Financial Statements for the year ended 31 December 2011 Contents Independent Auditors Report 3 Consolidated Income Statement
More informationDOING BUSINESS IN DENMARK 2005/2006
DOING BUSINESS IN DENMARK 2005/2006 INTRODUCTION The purpose of this publication is to give an introduction to those considering conducting business in Denmark, either by establishing a company or a branch
More informationCyprus Romania Tax Treaties
Cyprus Romania Tax Treaties AGREEMENT OF 16 TH NOVEMBER, 1981 This is the Convention between the Government of The Socialist Republic of Romania and the Government of the Republic of Cyprus for the avoidance
More informationMyanmar has a small tax treaty network with
A look at international tax planning in Myanmar The opening of Myanmar to the world and its ongoing transition to an open economy has generated a huge amount of interest from multinational companies looking
More informationCyprus Tax Update. Kyiv May 2018
Cyprus Tax Update Kyiv May 2018 Today s agenda 1. Snapshot of Cyprus tax system 2. Developments affecting the Cyprus tax regime 3. Selected developments : a) ATAD b) TP 4. Selected structures 5. Expected
More informationSOUTH AFRICA GLOBAL GUIDE TO M&A TAX: 2017 EDITION
SOUTH AFRICA 1 SOUTH AFRICA INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? In the 2016 Budget Review, tax avoidance
More informationANNUAL REPORT OF TATA TECHNOLOGIES PTE LTD
ANNUAL REPORT OF TATA TECHNOLOGIES PTE LTD TATA TECHNOLOGIES PTE LTD (Incorporated in the Republic of Singapore) DIRECTORS' STATEMENT 2-3 INDEPENDENT AUDITOR S REPORT 4 STATEMENT OF COMPREHENSIVE INCOME
More informationIAS 12 Income Tax CPA Anthony M. Njiru September Uphold public interest
IAS 12 Income Tax CPA Anthony M. Njiru September 2018 Uphold public interest Objectives Overview of tax Current tax Summary Deferred tax Tax Expense is the aggregate amount included in the determination
More informationAmadeus IT Group, S.A. Auditors Report, Annual Accounts and Directors Report for the year ended December 31, 2014
Amadeus IT Group, S.A. Auditors Report, Annual Accounts and Directors Report for the year ended December 31, 2014 Amadeus IT Group, S.A. Auditors Report for the year ended December 31, 2014 Amadeus IT
More informationNOTES TO THE FINANCIAL STATEMENTS FOR THE YEAR ENDED 30 SEPTEMBER 2017
NOTES TO THE FINANCIAL STATEMENTS 1. ACCOUNTING POLICIES 1.1 Statement of compliance The consolidated (group) and separate (company) annual financial statements (financial statements) are stated in South
More informationCUMI MIDDLE EAST FZE RAK FREE TRADE ZONE RAS AL KHAIMAH UNITED ARAB EMIRATES FINANCIAL STATEMENTS AND REPORT OF THE AUDITOR FOR THE YEAR ENDED
CUMI MIDDLE EAST FZE RAK FREE TRADE ZONE RAS AL KHAIMAH UNITED ARAB EMIRATES FINANCIAL STATEMENTS AND REPORT OF THE AUDITOR FOR THE YEAR ENDED CUMI MIDDLE EAST FZE RAK FREE TRADE ZONE RAS AL KHAIMAH UNITED
More informationCONVENTION BETWEEN IRELAND AND THE REPUBLIC OF GHANA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES
CONVENTION BETWEEN IRELAND AND THE REPUBLIC OF GHANA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME AND CAPITAL GAINS The Government of Ireland
More informationUNITED STATES MODEL INCOME TAX CONVENTION OF NOVEMBER 15, 2006
UNITED STATES MODEL INCOME TAX CONVENTION OF NOVEMBER 15, 2006 CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF ------- FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE
More informationCyprus Tax Booklet 2018
Cyprus Tax Booklet 2018 9 Vassili Michaelides Globalserve Business Centre, 3026, Limassol-Cyprus P.O.Box 57019 3311 Limassol-Cyprus Tel. line: 00357 25 817181 Fax: (00357) 25 824055 E-mail: marketing@globalserve.com.cy,
More informationTAX IMPLICATIONS RELATED TO THE IMPLEMENTATION OF FRS 138: INTANGIBLE ASSETS
The Malaysian Institute of Certified Public Accountants TAX IMPLICATIONS RELATED TO THE IMPLEMENTATION OF FRS 138: INTANGIBLE ASSETS Prepared by: Joint Tax Working Group on FRS Contents Page No. 1 Introduction
More informationTHE GOVERNMENT OF CANADA AND THE GOVERNMENT OF THE STATE OF ISRAEL;
Convention between the Government of Canada and the Government of the State of Israel for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income THE GOVERNMENT
More informationAppendix 4E. Preliminary final report Current Reporting Period: 52 weeks ended 29 July 2017 Previous Corresponding Period: 53 weeks ended 30 July 2016
Appendix 4E (rule 4.3A) Preliminary final report 52 weeks ended on 29 July Appendix 4E Preliminary final report Current Reporting Period: 52 weeks ended 29 July Previous Corresponding Period: 53 weeks
More informationCYPRUS TAX SYSTEM BRIEF INFORMATION FOR TAX YEAR 2015
CYPRUS TAX SYSTEM BRIEF INFORMATION FOR TAX YEAR 2015 The information contained in this booklet is accurate as at the date of its publication. It is based on information available at that time and is designed
More informationRBC Information Systems. Consolidated Financial Statements for the year ended 31 December 2003
Consolidated Financial Statements for the year ended 31 December 2003 Contents Independent Auditor s Report 3 Consolidated Income Statement 4 Consolidated Balance Sheet 5 Consolidated Statement of Cash
More informationUS Taxation- A Primer
WIRC of the ICAI- Seminar Series on Global Updates- I US Taxation- A Primer Presented by : 7 th May, 2011 CA. Shishir Lagu Session Overview Introduction Corporate Tax Overview Federal Income Tax State
More information