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

Similar documents
CY LEBANON BUSINESS FORUM. Presented by: Andreas Yiasemides CIFA Vice Chairman Partner PwC Cyprus - Head of Fund Services 14 June 2017

OUR FIRM S SERVICES INVESTMENT OPPORTUNITIES THROUGH CYPRUS

Cyprus EU Citizenship By Investment

Family Office kpmg.com.cy

Cyprus: A dynamic business and investment centre INTAX FORUM

Alternative Investment Funds - Cyprus

Alternative Investment Funds (AIFs) THE CYPRUS PERSPECTIVE. Author: Publication Date: Subject Area: Claire Metaxa 11 December 2018 Fund Industry

Cyprus as a modern alternative fund jurisdiction. Haris Kakoullis Partner KPMG Cyprus

Cyprus - Iran. The gateway to Iranian business

Cyprus Investment Programme

Cyprus Tax Residency and Non-Dom Rules

RECENT DEVELOPMENTS AND CYPRUS SECURITIES MARKET OPPORTUNITIES IN THE RUSSIAN AND CYPRIOT OPPORTUNITIES IN AN EVER

Cyprus: A place to relocate

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

Cyprus: Solutions for an evolving global funds industry

Cyprus Tax Guide for Investors

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

OBTAINING CYPRIOT CITIZENSHIP BY INVESTMENT

Now, Cyprus has further reinforced another aspect of its allure: that of personal taxation.

AIFMD, alternative asset management made in Gibraltar

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!

Cyprus International Tax & Business Environment. Tax

Cyprus, a prominent and credible international business centre.

The European Long Term Investment Fund (ELTIF) kpmg.com.cy

Global fund passport initiatives

CYPRUS AS A GATEWAY FOR INDIAN CROSS BORDER TRANSACTIONS

Cyprus Citizenship by Investment

Establishing a Fund in Gibraltar

CYPRUS ARMENIA: The gateway to Armenian business

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

Semi-Annual Report (Non-Audited) June 30, 2017

CYPRUS: AN EMERGING FUNDS JURISDICTION. Marios Tannousis Board Member & Secretary

CYPRUS INVESTMENT FIRM CIF

New Alternative Investment Funds Law of 2018

AIFMD Initial Guidance And Advice For The Sub-Threshold AIFM

LUGANO FUND FORUM, NOVEMBER 2013 SETTING UP A FUND IN LUXEMBOURG GIUSEPPE RIZZO. We go the extra mile

ICAV KEY CONSIDERATIONS

Irish Property Funds - An Introduction

PRACTICAL LAW INVESTMENT FUNDS MULTI-JURISDICTIONAL GUIDE The law and leading lawyers worldwide

Overview and key features 7. The regulated structuring options: the SICAR and the SIF 8. Authorisation 10. Regulatory supervision 11

Cyprus - Ukraine. A long lasting inheritance

Asset management and funds

Luxembourg Investment Vehicles SIF 2017 MILAN ROME LUXEMBOURG LONDON LUGANO DUBLIN SINGAPORE DUBAI

Cyprus: A dynamic business and investment centre

CYPRUS an Attractive International Business Centre

ERASMUS INTENSIVE PROGRAM 2012

Structures. Including Cyprus

A scrumptaxious proposition!

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

Leading Residence by Investment and similar programs. September 28-29, 2017

UCITS risk management as a precursor to risk management for alternative funds

A Guide to the Implications of the Alternative Investment Fund Managers Directive (AIFMD) for Annual Reports of Alternative Investment Funds (AIFs)

Cyprus - enhancing corporate and personal tax competitiveness

Cyprus A Streamlined P.R. Program

Bringing you up to speed.

Taxation of cross-border mergers and acquisitions

COVER PAGE. Claim for the refund, exemption or application of the reduced tax rate on income paid to non-residents

S E T T I N G U P A N A LT E R N AT I V E I N V E S T M E N T V E H I C L E I N L U X E M B O U R G

Wildgen s Newsletter

CYPRUS COMPANIES INFORMATION

PwC Israel Round Table Event

The Luxembourg 1988 Law on UCITS (Undertaking for Collective Investment in Transferable Securities) Part I

Ireland / Cayman : Overview & Outlook

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

CHRISTODOULOS G.VASSILIADES & CO. LLC

Despite being among the

1. Short overview of the Company Tax. Residence of Companies. The substance requirement can be described as follows :

CHEVALIER & SCIALES SICAR PRIVATE EQUITY INVESTMENT VEHICLE

Cypriot Citizenship and Permanent Residence Permit Your trusted advisors

Netherlands Country Report

Newsletter December 2013

BUSINESS INSIGHTS Luxembourg, April 2018

Luxembourg Reserved Alternative Investment Fund (RAIF) - The best of two worlds?

CITIZENSHIP BY INVESTMENT

LUXEMBOURG PRIVATE EQUITY AND VENTURE CAPITAL

Luxembourg vehicles, Elements of the tool box for wealth / investments structuring in an international continuously changing environnement

21% 21% The Regional Finance Law provides that RAM can set a rate 20% lower than that applicable in Mainland Portugal 2.

Luxembourg implements AIFMD

AIFMD / UCITS and the Impact on Distribution

Luxembourg Investment Vehicles SICAR 2017 MILAN ROME LUXEMBOURG LONDON LUGANO DUBLIN SINGAPORE DUBAI

chevalier & sciales Comparison table of Luxembourg investment vehicles // luxembourg law firm

Investment funds in Gibraltar: regulatory overview

The Netherlands. Arcagna Attorneys at Law & Tax Advisers Arnold van der Smeede

Switzerland. Investment basics

CHEVALIER & SCIALES. the new luxembourg fund l aw. investment management. client memorandum 2011

YOUR ACCESS TO EUROPE CYPRUS INVESTMENT PROGRAMME

Cyprus The Gateway to Global Investments

AS A CREDIBLE FINANCIAL CENTRE

AIFMD: What it is and what to do.

Cross - border IPOs through Cyprus

European Holding: Formation Bank Accounts Trustee Service Administration & Support SWEDEN CYPRUS

BONN STEICHEN & PARTNERS

COSTAS TSIELEPIS & CO LTD

Hedge Funds Workshop

EFFECTS ON TRADING AND AND SOLUTIONS

QIAIFs Ireland s Regulated Alternative Fund Product

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

CYPRUS GLOBAL GUIDE TO M&A TAX: 2017 EDITION

ZURICH INVEST ICAV AUSTRIA COUNTRY SUPPLEMENT ADDITIONAL INFORMATION FOR INVESTORS IN AUSTRIA

The Optimus Retirement Benefit Schemes offer a wide range of pension solutions to meet your specific needs, from a one stop shop solution through to

Transcription:

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 location 2 EU-endorsed tax and legal framework 3 Business-friendly environment 4 Highly skilled human talent 5 Advanced infrastructure 6 High quality of life UCITS V Transposition Alternative Investment Funds Law 131(I) 2014 - Amendments 22 July 2017 Compliance with 2011/61/EU, local depository for AIFs PwC 1

The Cyprus Tax System at a Glance Taxation is based on residency status Tax residents are taxed on income earned both in Cyprus and abroad, whereas non-tax residents are taxed on certain income earned from Cypriot sources only 12,5% corporate tax on corporate trading profits as from 1.1.2013 Interest expense on 100% corporate acquisitions permitted Notional Interest Deduction on new equity invested Fully reformed Intellectual Property Regime Capital gains on sale of securities: 100% exemption Capital gains from the sale of immovable property situated outside Cyprus are tax exempt No withholding tax on outgoing payments (dividends-interest-royalties) No taxes on corporate dividend income or on profit on sale of shares Applicability of all EU directives Advance ruling practice exists UCITS V Transposition Alternative Investment Funds Law 131(I) 2014 - Amendments 22 July 2017 Compliance with 2011/61/EU, local depository for AIFs Extensive and constantly expanding network of attractive Double Tax Treaty network PwC 2

A Complete Framework for Funds and Management companies Modernization of the legal framework: Transposition of the UCITS IV Directive in 2012. Transposition of the Alternative Investment Funds Managers Directive (AIFMD) in 2013. Enactment of the Alternative Investment Funds Law in July 2014 (AIF Law) Modernized provisions of the AIF Law: Establishment of funds marketed to Professional/Well-Informed or Retail investors. Introduction of Umbrella Funds with segregated Investment Compartments (Sub-Funds). Establishment of the AIF with Limited Number of Persons, a slightly regulated structure with no initial capital requirements. PwC Regulatory Frameworks In the recent years the regulatory framework has seen tremendous changes: 2011 Alternative Investment Funds Managers Directive 2011/61/EU 2012 EU Regulation 231/2013 2014 CY Alternative Investment Funds Law 131(I) 2014 2017 Upcoming Events UCITS V Transposition Alternative Investment Funds Law 131(I) 2014 - Amendments 22 July 2017 Compliance with 2011/61/EU, local depository for AIFs 2009 UCITS IV Directive 2009/65/EC 2012 CY Open-Ended Undertakings for Collective Investment (UCI) Law of 2012 2013 CY Law 56(I)/2013 ON Alternative Investment Fund Managers 2016 CY Directive DI131-2014-05 regarding the Depositary of AIFs and AIFLNPs 3

The Structure Complia nce/aml Officer Portfolio Manager(s) Fund Admin Depository Professionals Involved Internal Auditor Risk Manager External Auditor Management Shareholder (Voting shares) The Fund AIF/AIFLNP Externally or self managed BOARD OF DIRECTORS INVESTORS (Investment Shares) COMPARTMENT 1 COMPARTMENT 2 COMPARTMENT 3 COMPARTMENT 4 Direct Investment and/or through SPVs PwC

Benefits for the Individuals Taxation is based on residency status Amendment of the tax residency definition One of the lowest income tax regimes in Europe with taxation reaching up to a maximum of 35% Dividend income and profit on sale of shares and other securities is tax exempt (non domiciled scheme) 50% tax exemption to all newcomers employees with annual salary at least 100.000 The VAT on acquisition of new residential property can be as low as 5% There are no transfer fees if the transaction is subject to VAT and 50% if not Immovable Property Tax (IPT) was fully abolished from January 2017 Can provide an EU Passport with a minimum investment of 2 million Tax on overseas pensions with one of the lowest rate 5% Pensions received from abroad by Cyprus Tax Residents are taxed at 5% Special reduced VAT for private yachts No inheritance ta. No wealth tax. No gift taxation UCITS V Transposition Alternative Investment Funds Law 131(I) 2014 - Amendments 22 July 2017 Compliance with 2011/61/EU, local depository for AIFs Individuals who are beneficiaries to a Trust, would be exempt from tax in Cyprus, to the extent PwC that the income at/from the Trust would be in the form of interest or dividends 5

Key Benefits of a Cypriot Fund Flexibility Any asset can be included in the investment strategy of the AIF Transparency Annual audited and half yearly reports to be sent to the CySEC and the Investors Cypriot Citizenship An Investor can apply for Cyprus Citizenship if makes an investment of 2m in a Cyprus AIF investing in Cyprus and take delight of all the benefits of an EU passport holder Regulations/Modern Legislation EU directives / business friendly jurisdiction (no onerous reporting requirements) Designed legislation to take into consideration new market realities and conditions Strong legal Framework based on UK Common Law Low set-up and operational costs Easy and cost efficient to set up and maintain Cyprus funds Tax benefits at the level of Investor and the Fund PwC

Exploitation of Troodos State Assets

1 st Transaction