Cyprus - Iran. The gateway to Iranian business

Size: px
Start display at page:

Download "Cyprus - Iran. The gateway to Iranian business"

Transcription

1 Cyprus - Iran

2 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 8 Notional Interest on Cyprus Financing Structures 9 Cyprus IP Box Regime 10 Capital Gains treatment 11 Cyprus Shipping: Tonnage Tax Scheme Cyprus International Trust Cyprus-Iran: Conclusion LEDRA HOUSE, 15 Agiou Pavlou Str. Agios Andreas 1105, Nicosia, Cyprus P. O. BOX: 24444, 1704 Nicosia, Cyprus cgv@vasslaw.net TEL: FAX:

3 INTRODUCTION Our long lasting and vast experience in international business consulting enables us to fully understand the needs of your business and contribute towards its success. This publication concentrates on the business development between Cyprus and Iran in the context of the Double Tax Treaty Agreement signed between the Government of the Republic of Cyprus and the Government of the Islamic Republic of Iran on 4 August This, along with strong incentives given by the Cyprus Government with regards to Cyprus citizenship by investment scheme is expected to further develop the cooperation potentials of the two contracting states in the upcoming years. Furthermore, we will endeavour to explain the benefits offered by Cyprus and the purposes served by Cypriot companies as Holding, Financing and Intellectual Property companies, as well as the benefits secured through the establishment of an International Cyprus Trust. 3

4 CYPRUS: TAX BENEFITS Cyprus provides for numerous tax benefits. Its tax and legal systems are in full compliance with the EU and the OECD s requirements against harmful tax practices. Cyprus has low corporation tax rate of 12,5%. Under the Cypriot Corporation Tax, inbound dividends are not taxable with easily met conditions. Outbound dividends are not subject to any withholding taxes. They are only subject to the Special Defence Contribution (SDC) if the dividends are distributed to Cyprus tax resident individuals. However, if outbound dividends are distributed to non-cyprus tax Residents or to non-domicile Cyprus tax resident individuals are not taxable. Cyprus does not impose capital gains tax on the disposal of shares unless it relates to immovable property situated in Cyprus. If the immovable property is located outside of Cyprus, such gains are exempt. Since 2004, Cyprus has been an official member of the EU and, as required by law, has implemented all EU Directives. This has resulted in Cyprus obtaining all relevant tax benefits granted to intra-community transactions. In addition, Cyprus has expanded the applicability of the tax benefits obtained by the EU Directives to all third countries through the incorporation of relevant EU Directive provisions into its national legislation. EU Directives that have been implemented are the Parent Subsidiary Directive, the Merger Directive, the Tax Savings Directive, the Interest and Royalties Directive and the Administrative Cooperation in the field of Taxation. Cyprus provides for no inheritance tax; Cyprus has concluded an extensive number of Double Tax Treaties (DTTs) for the avoidance of double taxation. Tax paid abroad can be credited against any tax payable in Cyprus on such income, irrespective of any Double Tax Treaty. CYPRUS: FURTHER BENEFITS It is important to mention that Cyprus is a common law jurisdiction and its Companies Law is based on the UK Companies Act of During the last few decades Cyprus has become known as an international financial center, located at the crossroads of three continents: Europe, Asia and Africa. Overall, Cyprus offers a unique European base for international business companies. 4

5 NEW TREATY CYPRUS IRAN Cyprus and Iran took a significant step forward in establishing their bilateral relations. On 4th August 2015 a treaty for the avoidance of double taxation was signed and shall enter into force once each country completes the ratification process. The most significant provisions of the treaty are highlighted below: The withholding tax rate on dividends is 5% if the beneficial owner holds directly at least 25% of the capital of the dividend paying company. In all other cases the withholding tax rate is 10%. Currently Cyprus and Iran do not impose withholding tax on dividends. The treaty rates will apply only when any or both of the two states impose withholding tax in their domestic legislation. The withholding tax rate on interest is 5%. The withholding tax rate on royalties is 6%. The permanent establishment definition included in the treaty is in line with the meaning provided in the OECD Model Tax Convention. In particular, under the treaty, a building site or construction or installation project or any supervisory activities in connection with such site or project, constitutes a permanent establishment only if its duration extends beyond 12 months. Gains from the disposal of immovable property may be taxed in the country where the immovable property is situated. Gains from the disposal of shares, deriving more than 50% of their value directly or indirectly from immovable property may be taxed in the country in which the immovable property is situated. Cyprus- Iran: Double Tax Treaty Under the Cyprus Income Tax Law, it is vital to outline the beneficial tax terms that apply for dividends, interest and royalties paid from Cyprus. Dividends: 0% withholding tax Interest : 0% withholding tax Royalties: 0% withholding tax Royalty payments are exempt from any withholding taxes provided that were exercised outside Cyprus. 5

6 CYPRUS HOLDING COMPANY Principal Company/Ownership 100% No participation requirements No holding requirements Cyprus Holding Co Iranian Co Investments Dividends No Withholding tax Dividends No Withholding tax CYPRUS treatment: Dividends received: Dividends are not subject to corporation tax and are likely to be exempt from SDC Dividends paid: 0% withholding tax IRANIAN treatment: Dividends paid: 0% withholding tax on dividends paid by an Iranian Subsidiary to a Cyprus Holding company. Interest paid: 5% withholding tax on interest paid. Royalties paid: 6% on royalties paid. Cyprus companies can effectively be used as holding entities for Iranian companies involved in international cross border transactions. In the diagram above, Cyprus company holds 100% participation in an Iranian company conducting various investments. From a Cyprus perspective, no participation or holding requirements exist in order to obtain tax benefits. Incoming dividends from Iran, are exempt from Cyprus corporation tax and may also be exempt from SDC provided that one of the below is met: > no more than 50% of the Iranian Company s activities lead to investment income; or > the foreign tax rate must not be significantly lower than the tax payable in Cyprus (In practice lower than 6,25%). 0% withholding tax is imposed on dividends distributed by the Cypriot companies to the Iranian companies as per the provisions of the Cypriot tax legislation. 6

7 CYPRUS Iranian Co/persons HOLDING COMPANY Dividends IN INTERNATIONAL CYPRUS HOLDING Co INVESTMENTS Dividends Investments RUSSIA INDIA USA SOUTH AFRICA MIDDLE EAST CHINA EU CYPRUS treatment: Dividends received: Dividends are not subject to tax in Cyprus with easily met conditions CYPRUS treatment: Dividends paid: 0% withholding tax at the level of Cyprus REGION Russia India USA Ukraine Middle East South Africa China EU (Application of EU Directives) DIVIDENDS 5-10% 10-15% 5-15% 5-15% 0-15% 5-10% 10% 0% INTEREST 0% 0-10% 0-10% 2% 0-15% 0% 10% 0% Royalties 0% 15% 0% 5-10% 0-15% 0% 10% 0% 7

8 CYPRUS BACK- TO-BACK FINANCING COMPANY INTEREST Taxable interest income Principal Co Cyprus Financing Co INTEREST Iranian Co LOAN LOAN CYPRUS FINANCING COMPANY Financing the group companies in two ways: (a) by way of debt or (b) working capital; CYPRUS LEGISLATION Interest income received from intra-group lending bears 12,5% Corporation tax; No thin cap rules / no debt-to-equity restrictions; No Transfer Pricing legislation in place, however, the arm s length principle applies; Interest paid to non-resident creditors is not subject to any withholding taxes. Financing: Back-to-back The minimum profit margin on the lending interest rates acceptable by the Cypriot tax authorities is as follows: Less than Eur 50mln Eur 50mln - Eur 200mln Over than Eur 200mln 0.35% 0.25% 0.125% Cyprus companies are beneficially used as finance investment vehicles suitable for financing group of companies and resulting in an efficient accumulation of interest income. In the figure above, a Cyprus company is the subsidiary of a foreign company, and the parent company of an Iranian company. A loan from the Parent company can be passed down to the Iranian company with respective interest received. In Cyprus, interest income received from intra-group lending is liable to 12,5% corporation tax on the net minimum margins profit applicable. Additionally, interest paid to non-resident creditors is not subject to any withholding taxes. 8

9 NOTIONAL INTEREST DEDUCTION ON CYPRUS FINANCING STRUCTURES DIVIDENDS Taxable interest income INTEREST Principal Co Cyprus Financing Co Iranian Co EQUITY LOAN CYPRUS FINANCING COMPANY With the introduction of Notional Interest Deduction (NID), a deemed expense is allowed on the taxable income of a company resident in Cyprus and is calculated, by multiplying a reference interest rate on the New Capital that is issued by the company. The term new capital means the capital that has been contributed to the company after 1 January 2015 such as issue of share capital and share premium, if paid by the shareholder; The term " reference interest rate" is the ten year government bond rate of return of the State that the new capital is invested in, increased by 3%. However, the rate of return cannot be lower that the ten-year Cyprus Government bond increased by 3%. The allowable deemed expense on New Capital cannot exceed 80% of the taxable income. 80% is before the deduction of the deemed expense and in case of a tax loss the deemed expense on the New Capital cannot be claimed. CYPRUS LEGISLATION Principal company contributes funds to Cyprus Financing Co in the form of equity; Cyprus Financing Company lends the funds to the Iranian Company in the form of finance; Interest income received from lending is subject to 12,5% Corporation tax; Cyprus Financing company can claim notional interest deduction on equity contributed by the Principal Company; 80% maximum notional interest deduction on taxable profit reducing the effective tax rate in Cyprus to 2,5%; Dividends paid to non-resident Principal Co are not subject to any withholding taxes. Interest paid by the Iranian Company to Cyprus Financing Co is subject to 5% withholding tax in Iran; Overseas Tax paid in Iran can be credited against tax due in Cyprus Since,Cyprus Financing Co received the funds in the form of equity and then lends the funds to Iranian Co, no beneficial ownership issues should arise in Iran. 9

10 CYPRUS IP BOX REGIME Cyprus IP Tax Regime Cyprus offers an advantageous regime for business investing in IP rights; Dividends Tax incentives Net royalty profits are subject to 12,5% corporation tax. However, 80% of any income generated from Intellectual Property owned by Cypriot resident companies is exempt from Corporation tax reaching at a maximum effective tax rate of 2,5%; Royalties Principal Co Cyprus IP Co Iranian Co Contribution of IP Licence IP 80% of profit generated from the disposal of IP by Cypriot resident companies is exempt from corporation tax; Gains on the sale of shares of Cyprus IP Co is exempt from corporation tax; In the diagram above, a Cyprus IP Company licenses its IP Iranian Co and in return it receives royalty income which will be taxed in Cyprus under corporation tax reaching at a maximum effective rate of 2,5%. Qualifying IP rights/ What kind of intangibles does the Cypriot IP Box cover? The Cyprus IP Box regime applies to a wide range of IP rights falling within the meaning of the Patent Law, the Intellectual Property Rights Law and the Trademarks Law. More specifically but not exhaustively the list includes intangible assets such as: Copyrights taking the form of literary works, dramatic works, musical works, scientific works, artistic works, sound recordings, films, broadcasts, published editions, databases, publications, Software programs, etc. Patented inventions etc. Trademarks and service marks, designs, models, etc. The efficient IP tax regime of Cyprus in conjunction with the protection offered by EU and all major IP treaties and protocols in which Cyprus is signatory is what makes Cyprus highly attractive for the acquisition or development of IP assets. For an IP to secure the above benefits the taxpayer should be the owner of the IP, officially registered either in Cyprus or abroad. 10

11 CAPITAL GAINS T REATMENT Principal Company/Ownership Dividends 100% Cyprus Holding Co Real Estate Property CYPRUS treatment: Disposal of immovable property held by Cyprus Holding Co, is exempt from tax in Cyprus, given that the immovable property is not situated in Cyprus. Gains on the sale of shares of Cyprus Holding Co are not subject to tax in Cyprus, given that does not hold any immovable property situated in Cyprus. Double Tax Convention treatment: Any gain derived by Cyprus Holding Co from the alienation of immovable property situated in Iran may be taxed in Iran. Any gain from the alienation of shares, deriving more than 50% of the value directly or indirectly from immovable Property situated in Iran may be taxed in Iran. 11

12 CYPRUS SHIPPING: THE TONNAGE TAX SYSTEM The Cypriot maritime registry is today one of the largest in the EU and the 10th largest worldwide. Moreover,Cyprus is a major ship management centre with several of the ship management companies operating on the island ranking among the largest in the world. The current Tonnage Tax (TT) system was adopted in 2010, has been fully approved by the European Commission, for the first time for an EU member state with an Open Registry. Under the TT system ship owning companies, charterers and ship management companies may be taxed on the net tonnage of their ship rather than with Corporation tax on their actual profits. Under the TT system the benefits may be extended to include the owners and charterers of ships with foreign flags, provided they are tax residents of Cyprus. Specific qualification requirements need to be satisfied in order to obtain the tax benefits granted under the TT system. Tax benefits under the Tonnage Tax System > No income tax and taxation on profits from the operation of a qualifying ship doing a qualifying activity, for the qualified ship owner and charterer > No income tax on ship management services on qualified ships, for the qualified ship manager > Tax free dividends from profits at all levels > Gains deriving from the disposal of or transfer of such vessels or the shares of the ship owning company are tax exempt > The emoluments of officers or of the crew on board of such qualified vessels are exempt from income tax > Bank interest earned on working capital or shipping revenue is tax exempt provided that the said capital/revenue is used by a qualifying owner/charterer/ship manager in the financing and the maintenance of a qualifying ship/ in expenses arising from a charter party/ in paying expenses relevant to the ship management of a qualifying ship > Allows mixed activities within a company, where the shipping activities are subject to Tonnage tax while the other activities are subject to corporation tax at 12,5%. 12

13 CYPRUS INTERNATIONAL TRUST Key legislation: Trusts are primarily enforceable pursuant to the Trustees Law of 1955, Cap. 193 (as amended). Specific legislation regarding Cyprus International Trusts: International Trusts Law, L. 69(I)/1992 (as amended). Key characteristics of Cyprus International Trusts (CITs) pursuant to L. 69 (I)/1992 (as amended): The settlor (being a natural or legal person) is not a Cyprus tax-resident in the calendar year which precedes the year of creation of the CIT; At least one of the trustees must be a Cyprus tax-resident throughout the duration of the CIT; and This criterion ensures that the courts of Cyprus have effective jurisdiction over the trust. None of the beneficiaries (natural or legal persons) are Cyprus tax-residents in the calendar year which precedes the year of creation of the trust. The term Cyprus tax-resident is determined in Section 2 of the Income Tax Law, L.118(I)/2002 (as amended). Key Benefits of CITs: CITs are efficient wealth-management instruments ideal for high net-worth clients : -Income, gains and profit from non-cyprus sources are exempt from income tax, capital gains, special contribution and other taxes paid in Cyprus (only taxed in Cyprus on Cyprus-sourced incomes); -Only the beneficiaries who are Cyprus tax-residents will be subject to tax on their worldwide income; and -No estate duty or inheritance tax is paid in Cyprus. Its duration is not subject to any limitation period. Offers stability and predictability: - any matters relating to the validity of the CIT or its administration, such as the trustee s fiduciary powers, will exclusively be governed by the laws of Cyprus; - powers and duties of protectors (if any) and trustees are exclusively interpreted with reference to the laws of Cyprus; and - succession/heirship, tax laws and judgments accorded by foreign courts cannot affect the validity of a CIT or the transfer of trust prop erty; thus the beneficiaries interests are safeguarded from forced inheritance, claw-back rules and/or complicated situations like divorces, separations etc. It is a flexible vehicle: - Settlors have increased autonomy and flexibility to adapt the CIT to future circumstances and needs; and - trustees have investment powers equivalent to those of an absolute owner (e.g. may invest in property - moveable and immovable - both within Cyprus and abroad). 13

14 CYPRUS INTERNATIONAL TRUST TRUST BVI CO Consists of: Non-resident Settlor, At least one Cy tax-resident Trustee, Non-Cy tax-resident beneficiaries. Possibility for the settlor and beneficiaries to relocate to Cyprus after the establishment of the Cyprus International Trust. Alternatively, a Cyprus Holding Co can be used CYPRUS CO IRANIAN CO Cyprus taxation regime: No inheritance or estate duty tax; No withholding taxes on dividends received by Iranian Co; No withholding taxes on dividends, royalties and interest paid from Cyprus; 12,5% corporation tax on net profits; and No capital gains are taxable unless immovable property in Cyprus is involved. Investments 14

15 CYPRUS - IRAN CONCLUSION Cyprus is a modern country offering a unique European base for international business companies. It also constitutes a key to the Middle East, Asian and African markets. Countries like Iran are one of the upcoming business partners of Cyprus playing a leading role in direct foreign investments, both in and out of the country. Cyprus is located in a key geographical position and due to its vast treaty network is suitable for worldwide investments. Cyprus has become an attractive destination for structuring international investments with unique benefits. From an international investment perspective, Iranian companies, through Cyprus, can gain access to destinations with which they do not themselves maintain a treaty. The exploitation of such additional targeted markets can result in further global investments. In other words, Cyprus can be considered a passport for investments into the Central and Eastern European markets, Middle East, the Balkan markets and beyond. 15

16 Copyright 2015 CAUTION: The information in this booklet does not create a precedent. It is intended only as a general Guide and is not to be relied upon as the basis for any decision or outcome on the subject matter. Professional advice and consultation by Lawyers as applicable to the specific matter in question and in accordance to the laws and regulations in force at that time,must beobtained.

Cyprus - Ukraine. A long lasting inheritance

Cyprus - Ukraine. A long lasting inheritance Cyprus - Ukraine CONTENT Introduction 3 New Treaty Cyprus - Ukraine 3 Cyprus: Tax Benefits 4 Cyprus Holding Company 5 Cyprus Holding Company in International 6 Investments Cyprus Back-to-Back Financing

More information

CYPRUS ARMENIA: The gateway to Armenian business

CYPRUS ARMENIA: The gateway to Armenian business ARMENIA: 2013 CONTENTS Introduction 3 Cyprus: Tax Benefits 3 Cyprus Holding Company 5 Cyprus Holding Company In International 6 Investments Cyprus Back-to-back Financing 7 Cyprus Royalties Company 8 Capital

More information

CYPRUS AS A GATEWAY FOR INDIAN CROSS BORDER TRANSACTIONS

CYPRUS AS A GATEWAY FOR INDIAN CROSS BORDER TRANSACTIONS CONTENT Introduction 3 Cyprus: tax benefits Cyprus-India double tax treaty Cyprus Holding Company Cyprus Holding In International Investments Back-to-Back financing structures Cyprus royalties company

More information

OUR FIRM S SERVICES INVESTMENT OPPORTUNITIES THROUGH CYPRUS

OUR FIRM S SERVICES INVESTMENT OPPORTUNITIES THROUGH CYPRUS OUR FIRM S SERVICES INVESTMENT OPPORTUNITIES THROUGH CYPRUS 23 th November, 2017 PAPADEMETRIOU & PARTNERS LTD 26, Apollonos Str., P.O.Box 21865 1514 NICOSIA TEL.:00357 22667451 FAX.:00357 22668292 E-mail:pappan@cytanet.com.cy

More information

CHRISTODOULOS G.VASSILIADES & CO. LLC

CHRISTODOULOS G.VASSILIADES & CO. LLC CGV CHRISTODOULOS G.VASSILIADES & CO. LLC Advocates - Legal Consultants PROPOSED AMENDMENTS IN TAX LEGISLATION Introduction In an effort to improve the tax system in Cyprus, eliminate provisions which

More information

FOCUS INTERNATIONAL. October 2015 Cyprus edition. New legislation opens Cyprus for more business. Cyprus citizenship and residency schemes

FOCUS INTERNATIONAL. October 2015 Cyprus edition. New legislation opens Cyprus for more business. Cyprus citizenship and residency schemes October 2015 Cyprus edition INTERNATIONAL FOCUS New legislation opens Cyprus for more business 2 Cyprus citizenship and residency schemes 4 BEPS Action Plan 5 Follow us on LinkedIn and Twitter to access

More information

CYPRUS AND RUSSIA. Cyprus: the most trustworthy and tested jurisdiction for structuring investments in Russia

CYPRUS AND RUSSIA. Cyprus: the most trustworthy and tested jurisdiction for structuring investments in Russia BULLETIN 49 CYPRUS AND RUSSIA Cyprus: the most trustworthy and tested jurisdiction for structuring investments in Russia 1. Why choose Cyprus? Bilateral relations between Cyprus and Russia have always

More information

CYPRUS an Attractive International Business Centre

CYPRUS an Attractive International Business Centre PRIMEGLOBAL Southern Europe Meeting Andreas Koutounas FCCA Managing Director KKP Cyprus KKP CYP 1 Cyprus is well placed at the eastern-most point of Europe, occupying a key strategic position at the gateways

More information

Tax Planning and the Cyprus Holding Company

Tax 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 information

FOREWORD. Cyprus. Services provided by member firms include:

FOREWORD. 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 information

The Advantages of the Cyprus Tax System

The Advantages of the Cyprus Tax System 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

More information

CYPRUS TAX STRUCTURES

CYPRUS TAX STRUCTURES www.servpro.com.cy CYPRUS TAX STRUCTURES Serviced By PROFESSIONALS Holding Company (Inbound Investment) Non- Resident Company 0% / low withholding tax on dividends EU Parent Subsidiary Directive EU 0%

More information

Cyprus New Double Tax Treaties Become Effective

Cyprus 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 information

1 O u r P h i l o s o p h y C u s t o m e r s S a t i s f a c t i o n!

1 O u r P h i l o s o p h y C u s t o m e r s S a t i s f a c t i o n! 1 O u r P h i l o s o p h y C u s t o m e r s S a t i s f a c t i o n! CONTENTS Cyprus Facts 02 About our firm 03 Our services 04 Citizenship 05 PR VISA 06 TR VISA 07 CY Company 08 While in Cyprus 11 CYPRUS

More information

Cyprus Tax Residency and Non-Dom Rules

Cyprus Tax Residency and Non-Dom Rules Cyprus Tax Residency and Non-Dom Rules Tax Services May 2018 kpmg.com.cy Table of contents About Cyprus 3 The Corporate Tax System at a Glance 4 Tax Residency rules for Individuals 5 Non-Domicile rules

More information

Annual International Bar Association Conference Sydney, Australia. Recent Developments in International Taxation. Republic of Cyprus

Annual International Bar Association Conference Sydney, Australia. Recent Developments in International Taxation. Republic of Cyprus Annual International Bar Association Conference 2017 Sydney, Australia Recent Developments in International Taxation Republic of Cyprus Venetia Argyropoulou European University of Cyprus v.argyropoulou@euc.ac.cy

More information

Technical Newsletter. The Cyprus Holding Company. Seize the advantage of our expertise. Contents. Seize the Aspen advantage

Technical 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 information

International Taxation

International 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 information

Despite being among the

Despite being among the Cyprus an ideal holding company location Presented by Elias Neocleous and Olga Mikhailova, both partners at Andreas Neocleous & Co Despite being among the world s smallest countries, Cyprus has developed

More information

CYPRUS GLOBAL GUIDE TO M&A TAX: 2017 EDITION

CYPRUS GLOBAL GUIDE TO M&A TAX: 2017 EDITION CYPRUS 1 CYPRUS INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? The most recent developments which are relevant to M&A

More information

Cyprus - The gateway to global investments

Cyprus - 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 information

CYPRUS: INTERNATIONAL TRUSTS

CYPRUS: INTERNATIONAL TRUSTS CYPRUS: INTERNATIONAL TRUSTS 2013 LEDRA HOUSE 15 Ayiou Pavlou Street, Ayios Andreas 1105 Nicosia, Cyprus MAILING ADDRESS: P.O. Box 24444, 1703 Nicosia, Cyprus Tel: +357 22 556677 Fax: +357 22 556688 www.vasslaw.com

More information

Family Office kpmg.com.cy

Family Office kpmg.com.cy TAX SERVICES Family Office kpmg.com.cy 2 Family Office What is a Family Office? Family Office 3 A Family Office is the term given to a professionally managed set-up, established by wealthy families in

More information

Iceland Country Profile

Iceland Country Profile Iceland Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Iceland EU Member State No, however, Iceland is a Member State of the European

More information

DOING BUSINESS IN CYPRUS: CYPRUS COMPANY & TRUST FORMATION

DOING 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 information

Cyprus EU Citizenship By Investment

Cyprus EU Citizenship By Investment Cyprus EU Citizenship By Investment CYPRUS EU CITIZENSHIP BY INVESTMENT Cyprus became a member of the European Union in May 2004 and joined the EU Monetary Union in 2008 Cyprus has a stable legal and tax

More information

Charltons. Hong Kong. August Hong Kong And Russia Double Taxation Agreement Comes Into Force Introduction SOLICITORS

Charltons. 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 information

OUTLINE LIST OF ABBREVIATIONS... III LIST OF LEGAL REFERENCES...IV PART I. IMPLEMENTATION OF THE DIRECTIVE...V 1. INTRODUCTION...V 2. SCOPE...

OUTLINE LIST OF ABBREVIATIONS... III LIST OF LEGAL REFERENCES...IV PART I. IMPLEMENTATION OF THE DIRECTIVE...V 1. INTRODUCTION...V 2. SCOPE... CYPRUS 95 Page ii OUTLINE LIST OF ABBREVIATIONS... III LIST OF LEGAL REFERENCES...IV PART I. IMPLEMENTATION OF THE DIRECTIVE...V 1. INTRODUCTION...V 1.1. GENERAL INFORMATION ON THE IMPLEMENTATION OF THE

More information

CYPRUS COMPANIES INFORMATION

CYPRUS 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 information

Why Cyprus: Country Tax Profile

Why Cyprus: Country Tax Profile Why Cyprus: Country Tax Profile Operating through a company registered in Cyprus can significantly reduce the tax liability of the business and the ultimate shareholders, thus increasing the net return

More information

Cyprus Tax Guide for Investors

Cyprus 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 information

Holding Companies in Cyprus

Holding Companies in Cyprus Holding Companies in Cyprus 1 Contents Page # Introduction 3 Formation of a Holding Company 3 Taxation of Holding Company 4 Dividend Income 4 Capital Gains on Disposal of Shares 4 Repatriation of Dividends

More information

Effective. Tax Planning Structures

Effective. Tax Planning Structures Effective Tax Planning Structures DOUBLE TIER FINANCING Structure Layout Tax Benefits Settlements OffCo CyCo 1 CyCo 2 EQUITY Offshore company (OffCo) grants loan to Cyprus company (CyCo1). No need for

More information

Taxation of cross-border mergers and acquisitions

Taxation 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 information

Cyprus: A dynamic business and investment centre INTAX FORUM

Cyprus: A dynamic business and investment centre INTAX FORUM Cyprus: A dynamic business and investment centre INTAX FORUM Kiev, 29 th May 2017 Cyprus Investment Promotion Agency Cyprus: an international business hub A destination of choice for doing business A reputable

More information

INTERNATIONAL TAX STRUCTURING FOR INVESTING ADROAD INTERNATIONAL TAX CONFERENCE

INTERNATIONAL TAX STRUCTURING FOR INVESTING ADROAD INTERNATIONAL TAX CONFERENCE INTERNATIONAL TAX STRUCTURING FOR INVESTING ADROAD December 5, 2009 INTERNATIONAL TAX CONFERENCE - 2009 Shefali Goradia Partner, BMR Advisors OVERSEAS INVESTMENT KEY DRIVERS Access to Global Markets Inorganic

More information

Shipping in Cyprus. July 2016

Shipping in Cyprus. July 2016 Shipping in Cyprus July 2016 Shipping in Cyprus Cyprus holds a leading role in the shipping industry and ship management activities in South East Europe and is considered to be as one of the most attractive

More information

Cyprus 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 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 information

Cyprus has signed Double Tax Treaties (DTTs) and conventions with 61 countries.

Cyprus 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 information

Cyprus: (1) Citizenship (2) Permanent Residency (3) Real Estate (4) Tax Residency and Tax Incentives. Greece: In General & Investment Opportunities

Cyprus: (1) Citizenship (2) Permanent Residency (3) Real Estate (4) Tax Residency and Tax Incentives. Greece: In General & Investment Opportunities Cyprus: (1) Citizenship (2) Permanent Residency (3) Real Estate (4) Tax Residency and Tax Incentives Greece: In General & Investment Opportunities 1 Key Benefits: Free Movement of People: The Successful

More information

CYPRUS HOLDING COMPANIES

CYPRUS 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 information

T 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 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

CONNECTEDSKY LEGAL & CORPORATE CONSULTANTS LIMITED. Citizenship & Residency Schemes, and investment Opportunities in Cyprus

CONNECTEDSKY LEGAL & CORPORATE CONSULTANTS LIMITED. Citizenship & Residency Schemes, and investment Opportunities in Cyprus CONNECTEDSKY LEGAL & CORPORATE CONSULTANTS LIMITED Citizenship & Residency Schemes, and investment Opportunities in Cyprus Table of contents 1. Introducing ConnectedSky 2. Why Cyprus? 3. Citizenship and

More information

Cyprus Tax News Amendments to Cyprus s IP regime

Cyprus 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 information

Cyprus Country Profile

Cyprus 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 information

CYPRUS Tax Guide for Investors

CYPRUS Tax Guide for Investors CYPRUS Tax Guide for Investors 3 INDEX Introduction 1 Cyprus Tax Highlights 2015 2 Cyprus Holding Company 4 Cyprus IP Company 7 Cyprus Finance Company 9 Cyprus Investment Firms 11 Cyprus Licenced FX Company

More information

EFFECTS ON TRADING AND AND SOLUTIONS

EFFECTS ON TRADING AND AND SOLUTIONS TRANSFER PRICING EFFECTS ON TRADING AND FINANCING CYPRUS COMPANIES AND SOLUTIONS By Marios Efthymiou Managing Director DEFINITIONS Base erosion and profit shifting (BEPS) refers to tax avoidance strategies

More information

Convention between Canada and the Republic of Chile for the Avoidance of Double Taxation and the...

Convention 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 information

Cyprus Country Profile

Cyprus 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 information

Lex Mundi European Union: Accession States Tax Guide. CYPRUS Dr. K. Chrysostomides & Co.

Lex Mundi European Union: Accession States Tax Guide. CYPRUS Dr. K. Chrysostomides & Co. Lex Mundi European Union: Accession States Tax Guide CYPRUS Dr. K. Chrysostomides & Co. CONTACT INFORMATION: Chryso Pitsilli Dekatris Dr. K. Chrysostomides & Co. Tel: 357.22.777000 - Fax: 357.22.779939

More information

Cyprus Tax Booklet 2018

Cyprus 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 information

Montenegro Country Profile

Montenegro Country Profile Montenegro Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Montenegro EU Member State (EU candidate) Double Tax Treaties With: Albania

More information

The Cyprus Holding Company: A gateway to Europe, Asia, Africa and the Middle East

The Cyprus Holding Company: A gateway to Europe, Asia, Africa and the Middle East The Cyprus Holding Company: A gateway to Europe, Asia, Africa and the Middle East Tax Services vember 216 kpmg.com.cy 2 Section or Brochure name Table of contents The Cyprus Holding Company 3 Corporate

More information

Paid from Cyprus Divident (1) % Interest (1) %

Paid 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 information

Structures. Including Cyprus

Structures. 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 information

Serbia Country Profile

Serbia 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 information

George Campanellas, Board Member CIPA Tassos Yiasemides Partner KPMG Andreas Yiasemides Partner PWC Tassos Kotzanastasis Managing Director 8GCP

George Campanellas, Board Member CIPA Tassos Yiasemides Partner KPMG Andreas Yiasemides Partner PWC Tassos Kotzanastasis Managing Director 8GCP o o o o George Campanellas, Board Member CIPA Tassos Yiasemides Partner KPMG Andreas Yiasemides Partner PWC Tassos Kotzanastasis Managing Director 8GCP Competitive Advantages 1 EU Member/ Geostrategic

More information

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

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 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 information

INTRODUCTION. Situations should be viewed separately based on specific facts of each scenario.

INTRODUCTION. 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 information

A basic example illustrating the application of NID is provided further down.

A basic example illustrating the application of NID is provided further down. Information Sheet No. 64 Cyprus Tax Provision: Notional Interest Deduction Introduction As part of the overall effort to continuously improve and simplify the Cyprus tax system, as well as to remain a

More information

Cyprus has signed Double Tax Treaties (DTTs) and conventions with close to 60 countries.

Cyprus 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 information

Cyprus Tax Update. Kyiv May 2018

Cyprus 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 information

3.2. EU Interest-Royalty Directive Background and force

3.2. EU Interest-Royalty Directive Background and force 3.2. EU Interest-Royalty Directive 3.2.1. Background and force Force The Council Directive (2003/49/EC) on a Common System of Taxation Applicable to Interest and Royalty Payments Made between Associated

More information

AS A CREDIBLE FINANCIAL CENTRE

AS A CREDIBLE FINANCIAL CENTRE CYPRUS REPUTATION IS ENCHANCED AS A CREDIBLE FINANCIAL CENTRE Introduction On the 7th October 2010 the President of the Russian Federation Mr. Dmitry Medvedev during his official visit to Cyprus signed

More information

COMMENTARY ON THE ARTICLES OF THE ATAF MODEL TAX AGREEMENT FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO

COMMENTARY ON THE ARTICLES OF THE ATAF MODEL TAX AGREEMENT FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO COMMENTARY ON THE ARTICLES OF THE ATAF MODEL TAX AGREEMENT FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME 2 OVERVIEW The ATAF Model Tax Agreement

More information

Scheme for Naturalization of Investors in Cyprus by exception

Scheme for Naturalization of Investors in Cyprus by exception DECEMBER 2016 ISSUE 5 [STORY TITLE] [Story Subtitle or summary] Scheme for Naturalization of Investors in Cyprus by exception Invest in Cyprus Cyprus is the third largest island in the Mediterranean Sea,

More information

Cyprus Country Profile

Cyprus 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 information

Cyprus Double Tax Treaties

Cyprus 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 information

Maritime Cyprus Tax alert: New tonnage tax legislation introduced

Maritime Cyprus Tax alert: New tonnage tax legislation introduced Maritime Cyprus Tax alert: New tonnage tax legislation introduced May 2010 Kanaris Demetriades & Associates COMPLIANCE AUDIT TAX ADVISORY QUALITYSERVICEEXCELLENCE Cyprus: a well established shipping centre

More information

Tax on corporate transactions in Cyprus: overview

Tax on corporate transactions in Cyprus: overview Tax on corporate transactions in Cyprus: overview by Elias Neocleous and Elena Christodoulou, Elias Neocleous & Co LLC Country Q&A Law stated as at 01-Dec-2018 Cyprus A Q&A guide to tax on corporate transactions

More information

Parent Subsidiary Directive and Interest and Royalty Directive

Parent Subsidiary Directive and Interest and Royalty Directive Università Carlo Cattaneo LIUC International Tax Law a.a.2017/2018 Parent Subsidiary Directive and Interest and Royalty Directive Prof. Marco Cerrato Parent-Subsidiary Directive 2 The Directive in general

More information

TAX FACTS løggildir grannskoðarar

TAX FACTS løggildir grannskoðarar TAX FACTS 2016 løggildir grannskoðarar Tax facts 2016 2016 www.spekt.fo The information contained in this publication is only of a general nature. Although we endeavour to provide accurate and timely information,

More information

PAPER 2.03 CYPRUS OPTION

PAPER 2.03 CYPRUS OPTION THE ADVANCED DIPLOMA IN INTERNATIONAL TAXATION June 2017 PAPER 2.03 CYPRUS OPTION SUGGESTED SOLUTIONS PART A Question 1 Part 1 Tax residency of physical persons is determined by reference to physical presence

More information

Overview. Provisions of the UN / OECD Models dealing with the taxation of rent/royalties. Art. 6

Overview. Provisions of the UN / OECD Models dealing with the taxation of rent/royalties. Art. 6 Overview Analysis of the treatment of rent and royalty payments under the provisions of tax treaties Tuesday, 7 November 2017 (Session 2) Provisions of the UN and OECD Models dealing with the taxation

More information

Legal Aspects of Doing Business in Austria

Legal Aspects of Doing Business in Austria Lansky, Ganzger + partners Legal Aspects of Doing Business in Austria Cross-Border Business Activities through the Vienna Hub Best Location for your Holding Mag. Ronald Frankl Tel Aviv, May 26 th 2013

More information

Structuring Investments into Africa: Tax and BITs Aspects

Structuring Investments into Africa: Tax and BITs Aspects Structuring Investments into Africa: Tax and BITs Aspects February 2015 Structuring Investments into Africa Tax is, of course, only one of many elements to consider when planning cross-border investments.

More information

Mongolia Tax Profile. Produced in conjunction with the KPMG Asia Pacific Tax Centre. Updated: June 2015

Mongolia Tax Profile. Produced in conjunction with the KPMG Asia Pacific Tax Centre. Updated: June 2015 Mongolia Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: June 2015 Contents 1 Corporate Income Tax 1 2 Income Tax Treaties for the Avoidance of Double Taxation 6 3 Indirect

More information

Tax Alert Ratification of New Double Tax Treaty Between Ukraine and Cyprus

Tax Alert Ratification of New Double Tax Treaty Between Ukraine and Cyprus Tax Alert Ratification of New Double Tax Treaty Between Ukraine and Cyprus On 4 July 2013, the Verkhovna Rada of Ukraine accepted the Law of Ukraine On Ratification of a Convention between the Government

More information

New United States-Japan Tax Treaty Enters Into Force: New Withholding Rates Take Effect on July 1, 2004

New United States-Japan Tax Treaty Enters Into Force: New Withholding Rates Take Effect on July 1, 2004 New United States-Japan Tax Treaty Enters Into Force: New Withholding Rates Take Effect on July 1, 2004 4/2/2004 Client Alert On March 30, 2004, the Governments of the United States and Japan exchanged

More information

Advanced Taxation Cyprus (ATX- CYP) (P6)

Advanced Taxation Cyprus (ATX- CYP) (P6) June & December 2018 Advanced Taxation Cyprus (ATX- CYP) (P6) Syllabus and study guide Guide to structure of the syllabus and study guide Overall aim of the syllabus This explains briefly the overall objective

More information

OUTLINE LIST OF ABBREVIATIONS... IV LIST OF LEGAL REFERENCES... V

OUTLINE LIST OF ABBREVIATIONS... IV LIST OF LEGAL REFERENCES... V LUXEMBOURG 375 Page ii OUTLINE LIST OF ABBREVIATIONS... IV LIST OF LEGAL REFERENCES... V PART I. IMPLEMENTATION OF THE DIRECTIVE... VI 1. INTRODUCTION...VI 1.1. GENERAL INFORMATION ON THE IMPLEMENTATION

More information

TEI Tax Summit Asia Pacific. Hong Kong 31 August Baker & McKenzie

TEI Tax Summit Asia Pacific. Hong Kong 31 August Baker & McKenzie TEI Tax Summit 2016 Asia Pacific Hong Kong 31 August 2016 2015 Baker & McKenzie Session 4: What Do You Mean? The Evolution of the Definitions of IP and Royalties in Asia Speakers: Allen Tan, Singapore

More information

CYPRUS: 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 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 information

Exchange of Information: New regulations under the Russia Cyprus Double Tax Treaty

Exchange of Information: New regulations under the Russia Cyprus Double Tax Treaty Exchange of Information: New regulations under the Russia Cyprus Double Tax Treaty Ratification of the Russia Cyprus Protocol to the DTT and what to expect from Cyprus Tax Authorities 21 st June 2012 Background

More information

Cyprus Tax Guide kpmg.com.cy

Cyprus Tax Guide kpmg.com.cy Cyprus Tax Guide 215 kpmg.com.cy 215 KPMG Limited, a Cyprus limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (

More information

Myanmar has a small tax treaty network with

Myanmar 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 information

I N T E L L E C T U A L P R O P E R T Y R I G H T S T h e C y p r u s T a x P e r s p e c t i v e

I N T E L L E C T U A L P R O P E R T Y R I G H T S T h e C y p r u s T a x P e r s p e c t i v e I N T E L L E C T U A L P R O P E R T Y R I G H T S T h e C y p r u s T a x P e r s p e c t i v e The contents of this publication are for information purposes only and can not be construed as providing

More information

Who is liable. Land transfer fees. Notaries fees. Stamp duty. Debentures. Mortgages.

Who is liable. Land transfer fees. Notaries fees. Stamp duty. Debentures. Mortgages. Tax on Transactions 2009/10 Country Q&A Cyprus Cyprus Andreas Sofocleous & Co www.sofocleous.com.cy www.practicallaw.com/6-385-6761 TAX AUTHORITIES MAIN TAXES ON CORPORATE TRANSACTIONS 1. What are the

More information

Tax Flash CIT Reform Proposal

Tax Flash CIT Reform Proposal www.pwc.pt Tax Flash CIT Reform Proposal Cornerstones of this reform: simplification of tax compliance obligations, reduction of tax disputes, as well as a the intention to progressively reduce the corporate

More information

Cyprus Portugal Tax Treaties

Cyprus Portugal Tax Treaties Cyprus Portugal Tax Treaties AGREEMENT OF 19 TH NOVEMBER, 2012 This is a Convention between the Republic of Cyprus and the Portuguese Republic for the avoidance of double taxation and the prevention of

More information

Alter Domus CYPRUS NEWSLETTER. November 2017 WE RE WHERE YOU NEED US.

Alter Domus CYPRUS NEWSLETTER. November 2017 WE RE WHERE YOU NEED US. Alter Domus NEWSLETTER November 2017 WE RE WHERE YOU NEED US. Alter Domus Alter Domus is a fully integrated Fund and Corporate services provider, dedicated to international private equity & infrastructure

More information

COSTAS TSIELEPIS & CO LTD

COSTAS TSIELEPIS & CO LTD COSTAS TSIELEPIS & CO LTD TAX UPDATE Cyprus Tax Facts 2018 Volume 8, Issue 2 knowledge Facts, information and skills acquired through experience or education; the theoretical or practical understanding

More information

Tax Newsletter. Issue No. 1, March 2014 TAX NEWS 1. DOUBLE TAXATION TREATIES

Tax Newsletter. Issue No. 1, March 2014 TAX NEWS 1. DOUBLE TAXATION TREATIES Tax Newsletter Issue No. 1, March 2014 TAX NEWS 1. DOUBLE TAXATION TREATIES Over the last number of months, five new Double Taxation Treaties ( DTT ) have come into effect. The agreements are with Estonia,

More information

C Y P R U S SYNOPSIS. The main features of the Cyprus tax regime are as follows:

C Y P R U S SYNOPSIS. The main features of the Cyprus tax regime are as follows: 01.01.2013 C Y P R U S SYNOPSIS Cyprus is an island situated in the north eastern Mediterranean Sea at the crossroads of Europe, Asia and Africa. The capital city is Nicosia, which has a population of

More information

Contents. Andreas Athinodorou Managing Director International Tax Planning

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 information

Tax on corporate transactions in Cyprus: overview

Tax on corporate transactions in Cyprus: overview Tax on corporate transactions in Cyprus: overview Resource type: Country Q&A Status: Law stated as at 01-Nov-2015 Jurisdiction: Cyprus A Q&A guide to tax on corporate transactions in Cyprus. The Q&A gives

More information

DOING BUSINESS IN CYPRUS

DOING BUSINESS IN CYPRUS DOING BUSINESS IN CYPRUS CONTENTS 1 Introduction 3 2 Business environment 4 3 Foreign Investment 7 4 Setting up a Business 9 5 Labour 11 6 Taxation 13 7 Accounting & reporting 32 8 UHY Representation in

More information

Analysis: China Singapore Income Treaty Type of treaty: Income tax Based on the OECD Model Treaty Signed: July 11, 2007 Entry into force: September

Analysis: China Singapore Income Treaty Type of treaty: Income tax Based on the OECD Model Treaty Signed: July 11, 2007 Entry into force: September Analysis: China Singapore Income Treaty Type of treaty: Income tax Based on the OECD Model Treaty Signed: July 11, 2007 Entry into force: September 18, 2007 Effective date: In the P.R.C., from January

More information

CONVENTION 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 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 information

Recent Changes in the Cyprus Laws and changes in International tax structures

Recent Changes in the Cyprus Laws and changes in International tax structures Recent Changes in the Cyprus Laws and changes in International tax structures In July 2015 a package of amendments were submitted into Cyprus Parliament and have been voted into law. A second pack is expected

More information