Tag Archives: finance

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Brexit

CYPRUS – UNIQUE TAX ADVANTAGES WITHIN EUROPE POST BREXIT

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Cyprus: Europe’s Optimal Tax Regime. The synergy created by Cyprus’ modern, simple and attractive tax regime coupled with its advanced and adaptable English Common Law legal system have created the EU’s most efficient and effective tax regime in tax planning and asset protection. Why:

0% Tax on Dividends received – Dividends received by Cypriot tax resident companies are exempt from Cyprus tax (subject to minor exceptions). The extensive network of Double Tax Treaties (“DTTs”) allows beneficial treatment in respect of withholding taxes (“WHTs”) in the source country.

0% Withholding tax on Dividend payments – Dividends paid by a Cyprus tax resident company to its non-Cyprus resident shareholder(s) are not subject to any withholding tax in Cyprus. Thus the non-Cyprus resident shareholder of a Cyprus tax resident company receives the dividends free of any WHT.

0% Tax on trading/sale of titles or shares – The disposal or transfer of titles is exempt from all taxes. Titles are described as shares, bonds, debentures and similar titles as well as rights thereon (options, futures etc). Cyprus is, therefore, the jurisdiction of choice in respect to M&A transactions.

0% Capital Gains Tax is paid in Cyprus on the transfer of immovable property owned by a Cyprus tax resident company abroad (outside Cyprus).

0% Estate Duty is payable on the inheritance of shares in case of the death of a shareholder.

0% Inheritance Tax

0% Net Wealth Tax 

0% Property Tax

0% Tax on Reduction of Capital & Reduction of Share Premium Account 

0% Withholding Taxes on Interest and Royalties – There are no WHTs on interest payments made by a Cyprus tax resident company. There is also no WHT on royalties arising from sources outside Cyprus. 

Lowest uniform corporate tax rate in the EU – 12.5%

International Cyprus Trusts (CIT) may be established to hold the shares of Cyprus companies or simply used as an effective means of asset protection – CITs do not pay any taxation on their profits. Amendments to Cyprus’ Trust Law have restored the CIT as one of the most effective instruments available today.

Unilateral Tax Credit Relief – Unilateral tax credits are granted on any tax paid abroad to any foreign country, irrespective of whether Cyprus has a DTT or not. In such a case the income is not taxed twice but only once.

Double Tax Treaties – Cyprus has an impressive and continually growing network of DTTs, a Cyprus company can benefit from the EU Directives to eliminate WHTs when collecting income from the EU. Unilateral tax credit on foreign taxes withheld at source is also available.

Anonymity of the beneficial owner – Anonymity is imperative to many investors, who do not wish to have their names appear on public record at the Registrar of Companies. In such instances it is possible to appoint a shareholder provided by LSTS, who will hold the shares on trust for the beneficial owner.

Losses can be carried forward and set off against future profits for the next five years.

Group relief – setting off the loss of one company with the profit of another is allowed provided both companies of the group are tax resident in Cyprus.

No Thin Capitalisation Rules – there are no provisions in the Law requiring companies to maintain a particular debt to equity ratio. Consequently, a Cyprus holding company may be capitalised with loans without any risk that interest paid at arms’ length to the parent company will not be deductible.

0% VAT for Holding Companies – holding activities fall outside the scope of the VAT in Cyprus and the Cyprus holding company engaged exclusively in holding activities is not entitled or obliged to register for VAT purposes.

0% Tax on Liquidation – A Cypriot holding company held by non-resident shareholders can cease operations in Cyprus and distribute assets to its shareholders in any form (dividends etc.) without any tax cost to the shareholders.

Non-Domicile Cyprus Tax Resident – Foreign nationals relocating to Cyprus (minimum 183 days) will obtain the status of a Non Domiciled individual, with significant tax benefits:

  • 0% Tax on dividends received by the individual in Cyprus
  • 0% Tax on interest in fixed deposits in Cyprus
  • Individual will only be taxed in Cyprus on their worldwide income
  • Reduced tax on rental income 

 

HOW LSTS CAN ASSIST YOU

LSTS may assist in:

  1. Assessment of your current business to determine income flows, intentions and ultimately to optimise tax gains and eliminate tax leaks.
  2. The establishment of a suitable Cypriot structure for minimising tax losses/leaks.
  3. Tax / Legal / Audit / Compliance / Fiduciary / Trust / Banking Services
  4. Assistance in availing you of the numerous tax advantages of Cypriot tax legislation.
  5. Keep you updated on all developments in Cypriot legislation.

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tax

CYPRUS – RUSSIAN DOUBLE TAX TREATY

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(ARTICLE 13 – ‘Capital Gains’ UPDATE) 

Capital gains tax on Cyprus shares holding immovable property in Russia has been postponed

UPDATE 29 DECEMBER 2016 

In an announcement by the Cyprus ministry of finance on 29 December 2016 it is stated that an agreement has been reached between the Russian Authorities and the Cyprus authorities for postponing the application of the Protocol amending Article 13 of the Cyprus – Russia double tax treaty (as amended in 2010) (the “Treaty”).

In accordance to Article 13 ‘Capital Gains’ of the Treaty the gains on sale of shares of a Cyprus company deriving more than 50% of their value from immovable property situated in Russia would be taxed in Russian Federation rather than Cyprus.  This clause was set to be effective from 1 January 2017.

Based, however, on the agreement reached on 29 December 2016 the application of Article 13 to the Treaty has been postponed and an additional Protocol to the Treaty will be released shortly providing that the application of the revised provisions of the Treaty will not apply until similar provisions are introduced in other bilateral double tax treaties between the Russian Federation and other European countries.

It should be noted that Cyprus does not levy any taxes on the sale of shares or similar titles.

 

 ANNOUNCEMENT PUBLISHED BY THE CYPRUS MINISTRY OF FINANCE

Announcement

Protocol amending Article 13 “Capital Gains” of the Agreement between 
the Government of the Republic of Cyprus and the Government of the 
Russian Federation for the Avoidance of Double Taxation with respect to
taxes on income and on capital.

The Ministry of Finance announces that an agreement has been reached between the Russian Authorities and the Authorities of Cyprus for postponing the application of the Protocol amending Article 13 of the Agreement between the Government of the Republic of Cyprus and the Government of the Russian Federation for the Avoidance of Double Taxation with respect to taxes on income and on capital, which was signed on October 7th , 2010.

In parallel, an additional Protocol is being finalised, providing for the application of the revised provisions of Article 13 of the said Agreement, until similar provisions are introduced in other bilateral Agreements for the Avoidance of Double Taxation between the Russian Federation and other European countries.

December 29th, 2016
MINISTRY OF FINANCE NICOSIA

HOW LSTS CAN ASSIST YOU

LSTS may assist in:

i.) The establishment of a suitable Cypriot structure for holding properties in Russia.

ii.) Provide further guidance on the new provisions to the new double tax treaty.

iii.) Keep you updated on the developments on the matter. 


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