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RUSSIA DEOFFSHORISATION On 25 November 2014, a law providing amendments to the Tax Code of the Russian Federation, introducing the concept of tax residency for legal entities and controlled foreign companies (“CFC”) (the “Law”), was signed by president Vladimir Putin. The Law came into effect 1 January 2015. (Russian Deoffshorisation) The law is set to establish rulesRead More
CYPRUS FINANCING TAX STRUCTURES BACK TO BACK LOANS One Tier Financing Company Provisions of the Law Article 33 of the Income Tax Law 2002 (the “Law”) gives the Inland Revenue Department the power to adjust transactions between connected companies, entities and individuals on an arm’s-length basis and to tax the resulting deemed profits, gains orRead More
THE CYPRUS INTERNATIONAL TRUST On 8 March 2012 the House of Representatives in Cyprus enacted the International Trusts (Amending) Law of 2012 effecting various structural amendments to the International Trusts Law of 1992. A new era began for Trusts in Cyprus giving a favourable trust regime by ensuring that international investors, settlors and beneficiaries enjoyRead More
CYPRUS UKRAINE DOUBLE TAX TREATY On 4 July 2013 the Ukrainian parliament approved the bill for ratification of the double tax treaty between Cyprus and Ukraine which was signed 8 November 2012 and which replaced the 1982 agreement between Cyprus and Soviet Union. This followed the initial failed attempt 18 June 2013 of the UkrainianRead More
DEOFFSHORISATION IMPACT AND SOLUTIONS In our previous newsletter named “Russian Federation Deoffshorisation“the provisions of the Law were analysed in detail. This newsletter, Deoffshorisation Impact and Solutions, provides possible solutions for achieving tax efficiency. The below should be read in conjunction with our previous Newsletter mentioned above. *imageRead More
SOLUTIONS TO POLISH CFC RULES Our analysis of the Polish CFC Rules in the new Polish Act which came into force 1 January 2015 appears below and is separated into two sections: I. CFC legislation in Poland and how this affects Cyprus. II. Suggested solution to the CFC provisions. *imageRead More
Private Placement Life Insurance “IT’S viewed as an insider’s secret for the affluent” New York Times 2011 “A tremendous appeal of private placement life insurance is that the investment options can be tailored to a high-end client’s needs and the cost of insurance per dollar of coverage is much reduced.” Forbes 2013 “Private placement lifeRead More
CYPRUS SERBIA DOUBLE TAX TREATY Presentation Contents: Cyprus Tax Provisions as a Holding Jurisdiction Cyprus Tax Provisions as a Financing Jurisdiction Cyprus Tax Provisions as an Intellectual Property Vehicle Cyprus Tax Provisions – Payments by Serbia Cyprus Serbia Double Tax Treaty Cyprus Structures Investing in Serbia *imageRead More
CYPRUS RUSSIA DOUBLE TAX TREATY Presentation Contents: Significant Developments in 2012 Cyprus Tax Provisions as a Holding Jurisdiction Cyprus Tax Provisions as a Financing Jurisdiction Cyprus Tax Provisions as an Intellectual Property Vehicle Cyprus Tax Provisions – Payments by Russia Cyprus Russia Double Tax Treaty – Effective changes Cyprus Structures in Investing in Russia *imageRead More