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| New Protocol to the Cyprus - Russian Federation Double Tax | 05/06/2009 |
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| On 16th April 2009, government representatives from both Cyprus and the Russian Federation signed a protocol to the 1998 double tax treaty between the two countries. The protocol is expected to come into effect on 1st January 2010 subject to its ratification by both governments in 2009. |
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| Cross Border Mergers in Cyprus | 02/09/2008 |
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| Nancy Charalambous |
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| Law N.186(I)/2007 has inserted new provisions in the Cyprus Companies Law, Cap113 (the “Law”), bringing the same in line with the provisions of Directive 2005/56/EC on cross border mergers of limited liability companies (the “Directive”) and facilitating cross border mergers with Cyprus companies, transfers into Cyprus of the registered office of foreign companies and the formation of the Societas Europae (“SE”), the last two having controversially preceded the implementation provisions on cross border mergers. |
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| The Cyprus Holding Company | 01/09/2008 |
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| Emily Yiolitis |
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| The purpose of this book is to highlight certain features of the Cyprus tax legislation which make the Cyprus Holding Company a particularly attractive vehicle for the consolidation of one’s assets in a tax efficient manner. It does not purport to be an exhaustive guide to the Cyprus legislation in this context and should not be relied upon as giving any advice or making any recommendations. |
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| The Cyprus Holding Company | 01/09/2008 |
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| Aristodemou Loizides Yiolitis LLC |
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| Why set up a holding company? In essence, holding companies are set up as an effective means of consolidating ownership of operating subsidiaries. Deciding where to set up a holding company is not always a tax driven exercise, but usually, a business entrepreneur will seek the most tax effective means of consolidating ownership of his or her operating subsidiaries. As aptly stated by Lord Tomlin in IRC v Duke of Westminster, |
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| Memorandum on the Cyprus Societas Europaea | 01/09/2008 |
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| The ability to set up the new legal vehicle of the European Company or “Societas Europaea” as it is called is a reality in Cyprus. Cyprus has successfully implemented a number of Statutes and amendment legislation giving effect to the EC Regulation No. 2157/2001 on the European Company Statute (“SE”) (the “EC Regulation”) and the Council Directive 2001/86/EC supplementing the European Company Statute with regard to the involvement of employees. |
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| Asset Protection and other Uses for Cyprus International Trusts | 01/09/2008 |
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| The use of the Trust as a vehicle of prudent international tax planning, and business structuring is constantly growing. Trusts have been created for many reasons, in an effort to reduce tax liabilities, to alter the devolution of assets on death, to avoid the inconvenience and publicity of probate and to protect assets from actual or potential creditors. As the title of the present article focuses on the popular “asset protection trust”, special attention will be paid to this “product” launched by legislators wishing to attract investors to their local market. |
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| Cyprus and the Special Contribution for the Defence Law | 01/09/2008 |
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| In 2003, in a pre-accession bid to join the EU, Cyprus reluctantly overhauled an offshore tax regime widely credited with sustaining the Cyprus economy after a crippling invasion which resulted in the territorial loss of the most prosperous part of the island and the relocation of a third of the island’s workforce. Two years on, the new income tax regime can only be described as a success in the face of adversity. Whereas many feared that increased regulation and the rise in corporate taxation for foreign owned businesses from 4.25% to 10% would deter foreign investment and would drive businesses to sunnier Caribbean climes, economic indicators today suggest a thriving services industry and a balanced and more attractive corporate tax regime. |
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| Inward investment to Europe - The new low tax landscape | 01/09/2008 |
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Zero tax jurisdictions no longer offer the appeal they used to. This is largely due to the wide array of defense tactics employed by high tax countries to dissuade their residents from using such zero tax jurisdictions. Such tactics include enlisting zero tax jurisdictions in national black lists, introducing controlled foreign company legislation, imposing exit taxes which tax unrealized gains on relocation of tax residence, enlisting the aid of transfer pricing rules, and implementing thin capitalization rules which ensure that interest payments are not translated into interest charges which are deductible for tax purposes. These tactics are not mutually exclusive and the pressure mounts on investors to move away from “penalised” jurisdictions to more reputable business centres. |
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