Tag Archives: Double Tax Treaty

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Cyprus Serbia Double Tax Treaty

Cyprus Serbia Double Tax Treaty

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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

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Cyprus Russia Double Tax Treaty

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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

The content is restricted for subscribed users only. Please register to our website or contact us on info@lsts.com.cy.

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Cyprus Poland Double Tax Treaty

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CYPRUS POLAND DOUBLE TAX TREATY

Presentation Contents:
  • Desired Attributes for a Holding Location
  • Cyprus Corporation Tax
  • Management Control
  • Cyprus Poland Double Tax Treaty [Jan 2013]
  • Benefits of Cyprus Entity
  • Cyprus Company Structures
  • Summary
The content is restricted for subscribed users only. Please register to our website or contact us on info@lsts.com.cy.

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Cyprus UK Double Tax Treaty

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Cyprus UK Double Tax Treaty

  • Cyprus UK Double Tax Treaty
  • Cyprus Holding Company
  • Cyprus Financing Company
  • Financing Company structure using Cyprus Incorporated Maltese Resident
  • Cyprus – Luxemburg Financing Structure
  • Cyprus Holding Company – Real Estate
  • Cyprus SPV for trading in “titles
  • Shipping companies in Cyprus
  • Key considerations
  • Summary

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Cyprus India Double Tax Treaty [Developments]

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CYPRUS INDIA DOUBLE TAX TREATY

News and Updates

HC dismisses plea against blacklisting of Cyprus [29/01/2015]

Cyprus accepts India’s condition [17/09/2014]

India-Cyprus tax treaty talks at an impasse [15/09/2014]

India Reviewing Cyprus Tax Treaty to Reduce Withholding Tax Issues [18/06/2014]

New double taxation avoidance agreement signed by September the latest [6/06/2014]

Finmin officials to visit Cyprus to negotiate tax agreement [24/04/2014]

India-Cyprus double tax avoidance agreement to be finalised soon  [11/02/2014]

Decision to blacklist Cyprus for not providing tax data will hit developers and realty funds [6/02/2014]

India hopes for friendly resolution of tax snag [4/02/2014]

India in Talks with Mauritius and Cyprus to Prevent Tax Base Erosion  [10/01/2014]

India to withdraw order suspending tax benefits [4/12 /2013]

Lex Aspire Journal Vol. 1 – No. 6 December 2013 [12/12/13]

Stricter information sharing in India – Cyprus Treaty [5/12/2013]

Press Release from the Cyprus Ministry of Finance [3/12/2013]

  • The renegotiation of the existing DTT between Cyprus and India which entered into force on 21st December 1994, a new DTT is expected to be finalised soon.
  • It was further agreed that, based on the discussions held, once the notification of Cyprus as a “notified jurisdictional area” under section 94A of the Indian Income-tax Act 1961 is rescinded, it will be with retrospective effect from 1 November 2013, date when the notification of India was issued.

“Cyprus to conform with tax issues to avoid Indian & Russian black-list” [30/11/2013]

Cyprus allays investor fears after India rap”  [11/11/2013]

  • The Minister of Foreign Affairs of the Republic of Cyprus, Mr. Ioannis Kasoulides, held a bilateral meeting with the Minister of Foreign Affairs of India, Mr. Salman Khurshid, in the context of their participation in the Asia – Europe Meeting (ASEM) which took place in New Delhi between 11 – 12 November 2013.
  • The meeting was held in a very positive atmosphere, where the two Ministers reaffirmed the close and historic ties of friendship between Cyprus and India.
  • At the same time, the two sides agreed to remain committed in working together to resolve issues that arose regarding the Agreement on Avoidance of Double Taxation.

Although we are surprised by the unilateral action taken by a friendly state, India, towards Cyprus, we are confident that the matter will be resolved in November as Cyprus is committed to cooperating with India in a review of the Agreement. We are certain that much certainty will be instilled once the matter is resolved that will benefit both India and Cyprus.

1. It is important to stress that the Cyprus India DTT is still valid, further to the announcement made by the Cyprus Ministry of Finance;

2. Cyprus has taken the matter seriously and a visit is due in India in order to review the agreement and overcome the difficulties within November.

3. We are monitoring the matter and have contributed an article to Indian newspaper “Times of India: Cyprus allays investor fears after India rap” in this respect.

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Cyprus Ukraine Double Tax Treaty

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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 Ukrainian government to secure the majority of the parliamentary votes needed for the ratification. The law will enter into force when it is signed by the Ukrainian president and published in the Ukrainian government official journal. Provided that the notifications of the completion of all the required ratification procedures are exchanged between the two countries within 2013, then the new treaty will be applicable from 1 January 2014.

The new Cyprus Ukraine double tax treaty maintains almost all of the beneficial features of the previous treaty which set Cyprus as the preferred jurisdiction for investments into Ukraine, accounting for more than 25% of these, and at the same time puts an end to the long-standing uncertainty that existed due to the several years of negotiations between the two governments and the international pressure toward Ukraine to eliminate the, what was described as, “preferential” tax treaty with Cyprus.

The provisions of the new double tax treaty which safeguards Cyprus’ dominant position as the primary investment route into Ukraine are briefly set below:

Dividends, Interest and Royalties

Article 10: Withholding tax on dividend payments

Dividends paid are subject to a 5% withholding tax provided that the owner holds at least 20% of the capital of the company paying the dividend or has invested an amount of at least EUR100.000.

In all other cases a withholding tax of 15% applies.

Article 11: Withholding tax on interest payments

Interest paid is subject to a 2% withholding tax.

Article 12: Withholding tax on royalty payments

Royalties paid on income from copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience is subject to a 5% withholding tax. All other cases are subject to a 10% withholding tax.

Capital gains

Article 13: Capital gains tax

Even though as per Article 6 of the double tax treaty any income generated from immovable property located in either Cyprus or Ukraine may be subject to tax at the state where the immovable property is stated, Article 13 states that capital gains from a sale of shares (including capital gains on disposal of shares in immoveable property rich companies) is taxed in the country of residence of the seller. Since gains on sale of titles are exempt from Cyprus tax then there is no tax on the profits on sale of shares of Ukrainian companies holding immovable property.

Exchange of information

Article 24: Exchange of information

The provisions for the exchange of information use the exact wording of article 26 of the O.E.C.D. model and moreover the double tax treaty states all the necessary steps relating to the request for information in order to demonstrate the foreseeable relevance of the requested information. These steps will provide to the taxpayers maximum protection against misuse of the clause.

The information to be supplied includes;

i.    the identity of the person under examination;

ii.  a description of the information requested including the form and manner in which the requesting state wishes to receive the information;

iii.   the tax purpose for which the information is sought;

iv.   the grounds for believing that the requested information is held by the contracting state to which

v.    the request is addressed, or is in the possession or under the control of a person within its jurisdiction;

vi.   the name and address of any person who may hold the information requested, if known;

vii.  A written statement that the provision of such information is in compliance with the legislation and  the administrative practices of the requesting state and that if the requested information was within the state in question, the competent authority may procure the information in accordance with its own laws and its ordinary administrative practices; and

viii. a written statement that the contracting state making the request has exhausted all other reasonable means of obtaining the requested information.

In Cyprus under the Assessment and Collection of Taxes Law the written approval of the Attorney General authorising ultimate disclosure is needed, and this will only provided only on a case by case basis. The Attorney General has not, to date, granted such authorisation in any case.

LSTS Group having vast experience in international tax structuring can assist you in your requirements in finding the optimal and tax efficient structure. Such examples are found on our presentation below. The presentation is available for subscribers.

The content is restricted for subscribed users only. Please register to our website or contact us on info@lsts.com.cy.

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