Cyprus after the storm Grant Thornton (Cyprus) Ltd. All rights reserved.

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Cyprus after the storm Grant Thornton (Cyprus) Ltd. All rights reserved."

Transcription

1 Cyprus after the storm

2 Purpose of presentation Brief introduction to Grant Thornton A few comments about the bail-in General introduction to Cyprus companies Outline of Cyprus and Cyprus tax Commonly-used structures involving Cyprus companies

3 ABOUT GRANT THORNTON CYPRUS

4 About Grant Thornton Cyprus one of the leading accounting firms in Cyprus, established in 1942 member of Grant Thornton International since 1982 offices in Nicosia and Limassol 7 partners, ~100 staff Assurance, Tax, Advisory and Outsourcing

5 Services provided to overseas clients Registration of new companies or transfer of companies from other providers Provision of directors, secretary, nominee and registered office Accounting and bookkeeping Audit and tax compliance Bank accounts opening and administering General support agreements, resolutions etc

6 THE CYPRUS BAIL-IN

7 The Cyprus bail-in Brief history Lack of regulation and easy access to low-interest loans meant that Cyprus banking sector expanded drastically, reaching 8xGDP =>Too big for the government to bail-out Exposure to Greek crisis (bonds and loans) caused massive losses, which meant that the banks could not meet capitalisation requirements Worried investors withdrew funds, causing liquidity problems => ELA Delay in action by previous government worsened the situation

8 The Cyprus bail-in Agreement with Eurogroup 25 th March bn package agreed Several structural changes, cost cuts, privatisations, tax changes (see later) Regarding banks: Only Laiki and Bank of Cyprus affected Secured deposits (< 100k) protected Resolution of Laiki Bank. Assets and secured deposits were transferred to Bank of Cyprus Reorganisation of Bank of Cyprus 47.5% haircut on unsecured deposits Temporary restrictions on movements of capital (to protect liquidity). New funds are not affected

9 The Cyprus bail-in The crisis has hit local economy (unemployment ~17%) 2014 will be a difficult year However, international business largely unaffected Light at the end of the tunnel: The numbers are small Natural gas reserves? Solution to Cyprus problem?

10 GENERAL INTRODUCTION TO CYPRUS COMPANIES The Cyprus legal system The private limited liability system Compliance KYC required

11 The Cyprus legal system Based on the English legal system Company Law based on UK Companies Act 1948, which has been amended extensively Most common form of legal entity is the Private Limited Company

12 Compliance requirements Obligation to prepare books and IFRS financial statements Small company audit exemption rarely used Provisional tax assessment due 1 st August and final tax return due 12 months after year-end Annual return to Registrar (and payment of 350)

13 Forming a Cyprus company KYC required Following documents are required for all UBOs (physical persons) who control >10% of share capital Passport copy, certified as true by Grant Thornton Utility bill as proof of residence (<6mths old) Letter of introduction from bank or Grant Thornton We will require proof of ownership of any intermediary companies Understanding of the business and source funds

14 THE CYPRUS TAX SYSTEM Main features Management and control Taxation of gains on "titles Taxation of dividend income Taxation of interest income Intellectual Property Other tax provisions Capital gains

15 Main features fully complies with EU and OECD regulations Double Tax Treaties with 50 countries one of the lowest corporation tax rate in Europe (12.5% effective 1 Jan 2013) gains on shares and most dividends exempt no withholding taxes on dividends and interest paid overseas (irrespective of DTT provisions).

16 Main features Capital Gains Tax only on Cyprus property protection of EU directives, even if no DTT no thin capitalisation rules no CFC rules no specific transfer pricing rules (arm s length principle applies for related parties) advanced tax rulings available

17 Taxation of gains on "titles" gains arising from the disposal of 'titles' are exempt from Cyprus tax (except if the company sold owns immovable property situated in Cyprus) the term titles has been defined by the Income Tax office as including a broad range of shares and similar financial instruments (more information on request)

18 Taxation of gains on "titles" ordinary shares founder s shares preference shares options on titles debentures bonds short positions on titles futures/forwards on titles swaps on titles depository receipts on titles (ADRs & GDRs) rights of claim on bonds and debentures.

19 Taxation of dividend Exempt from Income Tax Exempt from SDC (20%) unless: >50% of profits are generated from investment income (passive income) and tax suffered <6.25%

20 Taxation of interest income interest income which is considered part of ordinary activities is taxed at 12.5% on profits generated: Group financing vehicle (back-to-back loans) Financing company Company regularly trading in interest-bearing instruments (eg. bonds) in most other cases, 30% SDC is payable on the gross interest income (if received after 29 April 2013)

21 Intellectual Property new law since 2012 cost of acquisition can be amortised over 5 years exemption of 80% of net profit from the exploitation or disposal of IP balance is taxable at normal 12.5% corporate tax rate The above make the effective tax rate < 2.5%.

22 Other tax provisions no specific transfer pricing rules (OECD arm s length principle applies) tax losses can be carried forward for 5 years binding advance Tax Rulings are available

23 Summary full member of EU and compliant with OECD regulations well established and familiar legal framework one of the lowest corporation tax rate in EU dividends and profits on sale of shares normally exempt favourable tax treatment of interest, IP no withholding taxes on outward payments low bureaucracy and compliance costs

24 TAX PLANNING ILLUSTRATIONS

25 Holding company 0% on dividends Overseas investor (direct or indirect) Cyprus company Overseas company WHT as per DTT on dividends no minimum shareholding no tax in Cyprus on dividend income* no tax in Cyprus if overseas company is sold no CFC or thin-cap rules * Provided taxed at source at >6.25% or >50% non investment-related income.

26 Holding company Outbound investments 0% WHT on dividends 0% WHT on dividends EU Overseas company Cyprus company Non- EU WHT as per DTT on dividends WHT from non-eu according to DTT WHT from EU - 0% * no taxes in Cyprus on dividend income** profits on disposal of shares exempt from tax in Cyprus WHT on dividends to Cyprus depending on DTT no exit tax in Cyprus. * may have to prove substance ** Provided taxed at source at >6.25% or >50% not investment-related income

27 Real-estate company Overseas investor (direct or indirect) Cyprus company CyCo's can be disposed of without any tax in Cyprus No exit taxes in Cyprus. CyCo CyCo CyCo CyCo ORE* ORE ORE ORE * Overseas real estate

28 Back to back loan 0% WHT on interest Overseas investor (direct or indirect) Loan Cyprus company Loan Operating company WHT according to DTT low interest margin acceptable by Income Tax Office: 0-50m 0,35% 50m- 200m 0,25% > 200m 0,125% income tax at 12.5% on profits if operating company is in EU no WHT on interest payments to Cyprus (interest & royalty directive 2003/49/EC, where it is applied) no WHT on interest payment from Cyprus.

29 Finance company 0% WHT on interest Overseas investor (direct or indirect) Loan Cyprus company Loan Operating company WHT according to DTT Requirements: main activity is the provision of loans and acquisition of investments that generate interest income either interest income earned/total income > 60% or interest bearing assets or investments/total assets (at cost) >60% >75% of its interest income is not bank interest income gross total assets > 10m. interest income is subject to Income tax at 12.5% (not SDC) no WHT on interest payment from Cyprus.

30 Intellectual property company 0% on dividends Overseas investor (direct or indirect) Cyprus IP company Overseas operating company Cyprus IP company is the owner of IP which it licenses to overseas operating company, earning royalties 20% per year amortisation of acquisition cost 80% of IP profit exempt from tax Cyprus company may also license IP and sub-license to overseas country, paying 12.5% tax on the profits but with no exemption of 80%.

31 Conclusion Crisis has affected mainly the local business international business sector is healthy Banking arrangements abroad can be used Cyprus is one of the most attractive jurisdictions in terms of: Tax advantages Low bureaucracy and compliance Low cost of operation vs competitors Highly qualified and experienced labour force The biggest competitor to Cyprus today is Cyprus before the bail-in

32 Thank you! Any questions? Contact details: T E

GLOBAL GUIDE TO M&A TAX

GLOBAL GUIDE TO M&A TAX Quality tax advice, globally GLOBAL GUIDE TO M&A TAX 2013 EDITION www.taxand.com CYPRUS Cyprus From a Buyer s Perspective 1. What are the main differences among acquisitions made through a share deal versus

More information

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS LAWS AND DECREES The Income Tax (Amendment) Law of 2005 The Special Contribution for Defence (Amendment) Law of 2004 The Assessment and Collection

More information

The use of Cyprus structures in international tax planning

The use of Cyprus structures in international tax planning The use of Cyprus structures in international tax planning Tax and other advantages Tax planning ideas - structures 1 Terms of reference Purpose - basis of preparation - assumptions: This presentation

More information

Slovenia. Chapter. Avbreht, Zajc & Partners Ltd. 1 General: Treaties. 2 Transaction Taxes. Ursula Smuk

Slovenia. Chapter. Avbreht, Zajc & Partners Ltd. 1 General: Treaties. 2 Transaction Taxes. Ursula Smuk Chapter Avbreht, Zajc & Partners Ltd. Ursula Smuk 1 General: Treaties 1.1 How many income tax treaties are currently in force in? 44 income tax treaties are currently in force in. 1.2 Do they generally

More information

MALTA: A JURISDICTION OF CHOICE

MALTA: A JURISDICTION OF CHOICE MALTA: A JURISDICTION OF CHOICE LONDON - September 2012 Doing business from Malta can make a huge difference for your business UHY BUSINESS ADVISORY SERVICES LIMITED Updated September, 2012 An attractive

More information

COMPREHENSIVE BUSINESS SERVICES

COMPREHENSIVE BUSINESS SERVICES COMPREHENSIVE BUSINESS SERVICES CONTENTS About Cyprus... 02 Cyprus Tax Advantages... 04 About ANH Auditors - Consultants... 09 Audit... 10 Tax... 11 Business Consultancy... 12 Bookkeeping & Payroll...

More information

MALTA Jurisdictional Guide

MALTA Jurisdictional Guide MALTA Jurisdictional Guide GENERAL INFORMATION The Republic of Malta is situated in the centre of the Mediterranean, south of Sicily, east of Tunisia and north of Libya. Malta gained its independence from

More information

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Eric van Aalst Mark Riedy Citco Corporate Services Inc. Andrews Kurth LLP 450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Structuring International Operations

More information

CLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies

CLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies CORPORATE/LEGAL Incorporation time and costs Possible in 3 days app. EUR 2,500 Less than a week app. EUR 4,000 Up to 2 weeks

More information

The Advantages of the UK as a Location for a Holding Company. David Gibbs May 2015

The Advantages of the UK as a Location for a Holding Company. David Gibbs May 2015 The Advantages of the UK as a Location for a Holding Company David Gibbs May 2015 The UK is an attractive location to site an international holding company since not only does it offer a relatively stable

More information

The UK as a holding company location

The UK as a holding company location The UK as a holding company location Tax May 2013 kpmg.com A key ambition is to create the most competitive tax system in the G20. As well as lowering tax rates, the Government wants to make the UK the

More information

Greece Country Profile

Greece Country Profile Greece Country Profile EU Tax Centre March 2013 Key factors for efficient cross-border tax planning involving Greece EU Member State Double Tax Treaties With: Albania Estonia Lithuania Serbia Armenia Finland

More information

Real estate acquisition structures in Europe: the main tax issues

Real estate acquisition structures in Europe: the main tax issues Real estate acquisition structures in Europe: the main tax issues The increasing budget requirements of European countries and their implications for taxpayers CMS Annual Tax Conference - Thursday 9 February

More information

CYPRUS TAX CONSIDERATIONS

CYPRUS TAX CONSIDERATIONS TAXATION The following summary of material Cyprus, US federal income and United Kingdom tax consequences of ownership of the GDRs is based upon laws, regulations, decrees, rulings, income tax conventions

More information

PAPER IIA UNITED KINGDOM OPTION

PAPER IIA UNITED KINGDOM OPTION THE ADVANCED DIPLOMA IN INTERNATIONAL TAXATION June 2008 PAPER IIA UNITED KINGDOM OPTION ADVANCED INTERNATIONAL TAXATION TIME ALLOWED 3¼ HOURS You should answer FOUR out of the seven questions. Each question

More information

TAX CARD 2015 GREECE. Table of Contents

TAX CARD 2015 GREECE. Table of Contents GREECE TAX CARD TAX CARD 2015 GREECE Table of Contents 1. Individuals 1.1 Personal Income Tax 1.1.1 Employment and Pension Income 1.1.2 Income from Individual Practices and Freelance Professions 1.1.3

More information

Luxembourg holding companies: competitive and tax-efficient

Luxembourg holding companies: competitive and tax-efficient Luxembourg holding companies: competitive and tax-efficient June 2009 Table of contents 1. Introduction...3 2. Standard holding company (SOPARFI)...3 3. Double taxation treaties...3 4. Registration taxes...3

More information

CYPRUS: INTELLECTUAL PROPERTY

CYPRUS: INTELLECTUAL PROPERTY CYPRUS: INTELLECTUAL PROPERTY i n f o r m a t i o n b r o c h u r e THE NEW CYPRUS IP REGIME Cyprus is evolving into a leading IP location Why Cyprus? A reputable and fully transparent financial centre,

More information

TURKEY CORPORATE TAX (KURUMLAR VERGISI) The basic rate of corporation tax for resident and non-resident companies in Turkey is 20%.

TURKEY CORPORATE TAX (KURUMLAR VERGISI) The basic rate of corporation tax for resident and non-resident companies in Turkey is 20%. TURKEY CORPORATE TAX (KURUMLAR VERGISI) The basic rate of corporation tax for resident and non-resident companies in Turkey is 20%. Corporations in Turkey can be regarded as either limited or unlimited

More information

Holding companies in Ireland

Holding companies in Ireland Holding companies in Irel David Lawless Paul Moloney Dillon Eustace, Dublin Irel has long been a destination of choice for holding companies because of its low corporation tax rate of 12.5 percent, participation

More information

Customised Tax Solutions in Cyprus

Customised Tax Solutions in Cyprus Customised Tax Solutions in Cyprus 2 Contents A. About Orangefield-Cyprus 3 About us 4 Our Services 5 Cyprus An attractive jurisdiction 6 Real Estate Company Structure 14 Cyprus Company trading in shares

More information

UNITED KINGDOM LIMITED LIABILITY PARTNERSHIPS

UNITED KINGDOM LIMITED LIABILITY PARTNERSHIPS UNITED KINGDOM LIMITED LIABILITY PARTNERSHIPS Background A United Kingdom Limited Liability Partnership (LLP) has become a very popular vehicle for international commercial activity. This is because the

More information

Meridian Trust - Corporate & Fiduciary Services

Meridian Trust - Corporate & Fiduciary Services Meridian Trust - Corporate & Fiduciary Services It s not what we do, it s the way that we do it. 2 Meridian Trust is one of the leading corporate and fiduciary service providers in Cyprus. We have been

More information

Malta: an ideal Holding Company location

Malta: an ideal Holding Company location Malta: an ideal Holding Company location June 2010 TAX Malta a tried-and-tested holding company location Why Malta is a prime EU holding company location Access to Wide treaty network, the EU Parent-Subsidiary

More information

International Financial Accounting (IFA)

International Financial Accounting (IFA) International Financial Accounting (IFA) Preparation and presentation of Financial Statements DEPARTMENT OF BUSINESS AND LAW ROBERTO DI PIETRA SIENA, NOVEMBER 4, 2013 1 INTERNATIONAL FINANCIAL ACCOUNTING

More information

Private Company: SWEDEN

Private Company: SWEDEN Private Company: SWEDEN Limited Liability Company [Aktiebolag /AB] Partnership [Handelsbolag / HB] Limited Partnership [Kommanditbolag / KB] Formation and Registration Bank Accounts Professional Administration

More information

Tax Impacts to Structure Investments in Brazil Debt or Equity. Andrea Bazzo Lauletta November 2012

Tax Impacts to Structure Investments in Brazil Debt or Equity. Andrea Bazzo Lauletta November 2012 Tax Impacts to Structure Investments in Brazil Debt or Equity Andrea Bazzo Lauletta November 2012 Introduction Brazilian Scenario for Non-Resident Investments Brazil has a specific set of rules for non-resident

More information

Belgium in international tax planning

Belgium in international tax planning Belgium in international tax planning Presented by Bernard Peeters and Mieke Van Zandweghe, tax division at Tiberghien Belgium has improved its tax climate considerably in recent years. This may be illustrated

More information

CIMA Managerial Level Paper F2 FINANCIAL MANAGEMENT (REVISION SUMMARIES)

CIMA Managerial Level Paper F2 FINANCIAL MANAGEMENT (REVISION SUMMARIES) CIMA Managerial Level Paper F2 FINANCIAL MANAGEMENT (REVISION SUMMARIES) Chapter Title Page number 1 The regulatory framework 3 2 What is a group 9 3 Group accounts the statement of financial position

More information

INVESTING VIA THE NETHERLANDS OVERVIEW, FEATURES AND STRUCTURING POSSIBILITIES

INVESTING VIA THE NETHERLANDS OVERVIEW, FEATURES AND STRUCTURING POSSIBILITIES INVESTING VIA THE NETHERLANDS OVERVIEW, FEATURES AND STRUCTURING POSSIBILITIES Contents 1. General: Tax rate and tax base, tax treaty 2. Trademark structure 3. Interest free loan structure 4. Confidentiality

More information

Setting up your Business in Bulgaria Issues to consider

Setting up your Business in Bulgaria Issues to consider Bulgaria is a parliamentary republic situated in the heart of the Balkan Peninsula at the south - east part of Europe. It is a member of NATO since 2004 and of the European Union since 2007. The territory

More information

Value through Wealth Planning - Key trends in taxation of private investors. Prof. Pierre-Marie Glauser

Value through Wealth Planning - Key trends in taxation of private investors. Prof. Pierre-Marie Glauser Value through Wealth Planning - Key trends in Prof. Pierre-Marie Glauser Introduction (1) Wealth Management & Taxes Funds are Not declared Declared No taxes due Tax planning not necessary Relevant tax

More information

TOTAL A PRO PR SER SER CES LTD Secure your future

TOTAL A PRO PR SER SER CES LTD Secure your future TOTALPRO SERVICES LTD Secure your future International Tax Planning Company Formation and Administration Legal Services Banking Services Accounting and Audit Services Virtual Office Services About us Established

More information

INFORMATION SHEET NO.54. Setting up a Limited Liability Company in Poland December 2008

INFORMATION SHEET NO.54. Setting up a Limited Liability Company in Poland December 2008 INFORMATION SHEET NO.54 Setting up a Limited Liability Company in Poland December 2008 General The Commercial Companies Code (KSH) regulates all issues related to the establishment, activity and dissolution

More information

Company Formation in Austria. Tax l Accounting l Audit l Advisory

Company Formation in Austria. Tax l Accounting l Audit l Advisory Tax l Accounting l Audit l Advisory Company Formation in Austria When considering an investment abroad thought must be given to taxation of income received as dividends and interest as well as any capital

More information

A. INCOME TAX LAW 118(I)/2002 AS AMENDED

A. INCOME TAX LAW 118(I)/2002 AS AMENDED RELEVANT TO ACCA QUALIFICATION PAPER P6 (CYP) Amendments to the Paper P6 (CYP) syllabus Relevant for students taking exams in June or December 2013 The syllabus for the June and December 2013 papers for

More information

PRIVATE WEALTH MANAGEMENT COMPANIES

PRIVATE WEALTH MANAGEMENT COMPANIES PRIVATE WEALTH MANAGEMENT COMPANIES (SPFs) www.bdo.lu 2 Private Wealth Management Companies (SPFs) TABLE OF CONTENT FOREWORD 3 1. INTRODUCTION 4 2. ACTIVITIES OF AN SPF 2.1 Permitted activities...5 2.2

More information

Why Spain? Why Austria?

Why Spain? Why Austria? Briefing Overseas investments by Brazilian corporations Summary In this briefing we look at how the Austrian and Spanish domestic tax regimes for holding companies may be relevant when structuring international

More information

G8 Education Limited ABN: 95 123 828 553. Accounting Policies

G8 Education Limited ABN: 95 123 828 553. Accounting Policies G8 Education Limited ABN: 95 123 828 553 Accounting Policies Table of Contents Note 1: Summary of significant accounting policies... 3 (a) Basis of preparation... 3 (b) Principles of consolidation... 3

More information

Jordans Trust Company Limited Experts in creating and managing UK and Offshore companies and trusts

Jordans Trust Company Limited Experts in creating and managing UK and Offshore companies and trusts Jordans Trust Company Limited Experts in creating and managing UK and Offshore companies and trusts 1 Contents 3 Introduction 4 Jordans Trust Company in the UK 4 Benefits of forming a company in the UK

More information

Chapter. Statement of Cash Flows For Single Company

Chapter. Statement of Cash Flows For Single Company Chapter 4 Statement of Cash Flows For Single Company 4.1 Single company statement of cash flows Statement of cash flows are primary financial statements and are required along side the income statement

More information

Mexico Mergers and acquisitions involving Mexican assets

Mexico Mergers and acquisitions involving Mexican assets p84-88 IM&A - Chevez Rulz 21/03/2013 08:44 Page 84 Mexico Mergers and acquisitions involving Mexican assets by Ricardo Rendon and Layda Carcamo, Chevez, Ruiz, Zamarripa y Cia, S.C. Whenever a corporate

More information

Company Incorporation Forms

Company Incorporation Forms Company Incorporation Forms Registered office: Leicester Court, Suite 2, Edgar Bernard Street, Gzira GZR 1702, Malta. Telephone: +356 2730 0045 Facsimile: +356 2730 0049 E-mail: info@avanzia.com.mt http://www.avanzia.com.mt

More information

for residents and holding, property, treasury, trading, investments, manufacturing and services companies

for residents and holding, property, treasury, trading, investments, manufacturing and services companies ESTONIAN TAX SYSTEM for residents and holding, property, treasury, trading, investments, manufacturing and services companies Kaido Loor 18 June 2014 Estonian tax revenues TAXES Y2012 Share Income taxes

More information

YIOTA MILTIADOU & ASSOCIATES LLC

YIOTA MILTIADOU & ASSOCIATES LLC YIOTA MILTIADOU & ASSOCIATES LLC /;4.,908 0, /; 8478 DOING BUSINESS IN CYPRUS Tel: 00357 22498134, -22495374, Mob. Tel: 00357 99544511, -99438824 Fax: 00357 22313837 Web Site: www.ymiltiadou.com, E-mail:

More information

Israeli Tax Reform of 2005

Israeli Tax Reform of 2005 Israeli Tax Reform of 2005 The Israeli Parliament approved on July 25, 2005 the proposed income tax reform legislation (the Tax Reform ) pursuant to the recommendations of a committee appointed by the

More information

Spanish Tax Facts. The Expatriate Financial Guide to Spain

Spanish Tax Facts. The Expatriate Financial Guide to Spain The Expatriate Financial Guide to Spain Spanish Tax Facts Introduction Tax Year Assessment Basis Taxation in Spain occurs at a national level and at a regional ( Autonomous Community ) or municipal level.

More information

[LOGO] ROGERS COMMUNICATIONS INC. DIVIDEND REINVESTMENT PLAN. November 1, 2010

[LOGO] ROGERS COMMUNICATIONS INC. DIVIDEND REINVESTMENT PLAN. November 1, 2010 [LOGO] ROGERS COMMUNICATIONS INC. DIVIDEND REINVESTMENT PLAN November 1, 2010 Rogers Communications Inc. Dividend Reinvestment Plan Table of Contents SUMMARY... 3 DEFINITIONS... 4 ELIGIBILITY... 6 ENROLLMENT...

More information

Research, innovation and intellectual property in Luxembourg Lecomte & Partners Wildgen Partners in Law

Research, innovation and intellectual property in Luxembourg Lecomte & Partners Wildgen Partners in Law 2011 Research, innovation and intellectual property in Luxembourg Lecomte & Partners Wildgen Partners in Law Didier Lecomte Lecomte & Partners and Jean-Luc Dascotte Wildgen Partners in Law Luxembourg Research,

More information

Alderney The most competitive tax environment for egambling Operators - Page 1 of 7

Alderney The most competitive tax environment for egambling Operators - Page 1 of 7 ALDERNEY THE MOST COMPETITIVE TAX ENVIRONMENT FOR EGAMBLING OPERATORS The global egambling and taxation environment is evolving into one of an increasing number of regulated markets, seeking to impose

More information

Facts on Taxation in Denmark

Facts on Taxation in Denmark Facts on Taxation in Denmark Updated by Njord Law Firm, December 2015 www.investindk.com Contents Corporate taxation... 2 Tax liability for different corporate forms... 2 Full or limited tax liability...

More information

Appendix 3. The metric

Appendix 3. The metric Appendix 3 A consistent and useful effective tax rate methodology to assess the global tax performance of multinationals in relation to Australian-linked business operations 1 The purpose of this paper

More information

www.pwc.com.cy Cyprus The gateway to global investments

www.pwc.com.cy Cyprus The gateway to global investments www.pwc.com.cy Cyprus The gateway to global investments June 2014 Table of contents Foreword 1 Cyprus - The gateway to global investments 2 Local Market Opportunities 3 Main features of the Cyprus Tax

More information

AUGHTON AINSWORTH International Law Firm. 2 Merchants Quay Salford Quays Manchester, United Kingdom M50 3XR

AUGHTON AINSWORTH International Law Firm. 2 Merchants Quay Salford Quays Manchester, United Kingdom M50 3XR AUGHTON AINSWORTH International Law Firm 2 Merchants Quay Salford Quays Manchester, United Kingdom M50 3XR SETTING UP A BUSINESS IN THE UNITED KINGDOM Setting up a business Commonly used: Subsidiary Branch

More information

EFFECTIVE INTERNATIONAL INTELLECTUAL PROPERTY STRATEGIES TO MITIGATE U.S. TAXES

EFFECTIVE INTERNATIONAL INTELLECTUAL PROPERTY STRATEGIES TO MITIGATE U.S. TAXES EFFECTIVE INTERNATIONAL INTELLECTUAL PROPERTY STRATEGIES TO MITIGATE U.S. TAXES DENNIS S. FERNANDEZ INNA S. SHESTUL Fernandez & Associates, L.L.P. Fernandez & Associates, L.L.P. 1047 El Camino Real, Ste

More information

Macau SAR Tax Profile

Macau SAR Tax Profile Macau SAR Tax Profile Produced in conjunction with the KPMG Asia Pacific Tax Centre Updated: June 2015 Contents 1 Corporate Income Tax 1 2 Income Tax Treaties for the Avoidance of Double Taxation 5 3 Indirect

More information

UNIQUE TAX INCENTIVES in BELGIUM

UNIQUE TAX INCENTIVES in BELGIUM Federal Public Service Finance UNIQUE TAX INCENTIVES in BELGIUM 2014 Fiscal Department for Foreign Investments 25 22,3 23 24,2 26,3 25,1 28,2 31 31,3 34 34,3 37,1 37,9 36,5 38,6 40,1 2 Effective (Average)

More information

STANDARD LIFE INVESTMENTS PROPERTY INCOME TRUST LIMITED

STANDARD LIFE INVESTMENTS PROPERTY INCOME TRUST LIMITED This document is issued by Standard Life Investments Property Income Trust Limited (the "Company") and is made available by Standard Life Investments (Corporate Funds) Limited (the AIFM ) solely in order

More information

FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS

FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Chapter 10 FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Daniel Cassidy 1 10.1 INTRODUCTION Foreign companies with U.S. business transactions face various layers of taxation. These include income, sales,

More information

Cambodia Tax Profile. kpmg.com.kh

Cambodia Tax Profile. kpmg.com.kh Cambodia Tax Profile kpmg.com.kh Content 1 2 Tax Profile Income Tax Treaties for the Avoidance of Double Taxation 6 Indirect Tax (e.g. VAT/GST) 7 8 Personal Taxation Other Taxes 9 11 Free Trade Agreements

More information

ENCHANCING PORTUGUESE CORPORATE TAX REGIME

ENCHANCING PORTUGUESE CORPORATE TAX REGIME December 2013 ENCHANCING PORTUGUESE CORPORATE TAX REGIME The Parliament has approved the Portuguese Corporate Income Tax Reform. This Reform, which follow largely the recommendations of the Reform Commission,

More information

A quick residency guide for investors in real estate in Spain

A quick residency guide for investors in real estate in Spain GOLDEN VISA A quick residency guide for investors in real estate in Spain A quick residency guide for investors in real estate in Spain SPANISH GOLDEN VISAS This memo outlines the most relevant legal aspects

More information

TAXATION AND FOREIGN EXCHANGE

TAXATION AND FOREIGN EXCHANGE 1. TAXATION OF SECURITY HOLDERS The taxation of income and capital gains of holders of H Shares is subject to the laws and practices of the PRC and of jurisdictions in which holders of H Shares are resident

More information

Cross Border Tax Issues

Cross Border Tax Issues Cross Border Tax Issues By Reinhold G. Krahn December 2000 This is a general overview of the subject matter and should not be relied upon as legal advice or opinion. For specific legal advice on the information

More information

News Flash. September, 2015. Tax guide for property investment in Hungary

News Flash. September, 2015. Tax guide for property investment in Hungary News Flash September, 2015 Tax guide for property investment in Hungary Tax guide for property investment in Hungary In our current newsletter we would like to inform you about the most important taxation

More information

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income.

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income. Worldwide personal tax guide 2013 2014 The Netherlands Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Belastingdienst www.belastingdienst.nl

More information

Malta Companies in International Tax Structuring February 2015

Malta Companies in International Tax Structuring February 2015 INFORMATION SHEET No. 126 Malta in International Tax Structuring February 2015 Introduction Malta is a reputable EU business and financial centre with an attractive tax regime and sound legislative framework.

More information

International Accounting Standard 7 Statement of cash flows *

International Accounting Standard 7 Statement of cash flows * International Accounting Standard 7 Statement of cash flows * Objective Information about the cash flows of an entity is useful in providing users of financial statements with a basis to assess the ability

More information

Fact Sheet No.14 Corporate Tax and Depreciation

Fact Sheet No.14 Corporate Tax and Depreciation 14. Corporate Tax and Depreciation Corporate income tax is levied on income from the worldwide operations of Czech tax residents and on Czech-source income of Czech tax non-residents. Czech tax residents

More information

Netherlands. Croatia. Malta. Slovenia. Greece. Czech Republic. Portugal. Compulsory. households actual. social contributions.

Netherlands. Croatia. Malta. Slovenia. Greece. Czech Republic. Portugal. Compulsory. households actual. social contributions. Structure and development of tax revenues Table EL.: Revenue (% of GDP) 2004 2005 2006 2007 2008 2009 200 20 202 203 I. Indirect taxes : : 2.3 2.7 2.7.8 2.6 3.5 3. 3.4 VAT : : 6.8 7. 7.0 6.3 7. 7.2 7.

More information

Indian Accounting Standard (Ind AS) 7 Statement of Cash Flows

Indian Accounting Standard (Ind AS) 7 Statement of Cash Flows Contents Indian Accounting Standard (Ind AS) 7 Statement of Cash Flows Paragraphs OBJECTIVE SCOPE 1 3 BENEFITS OF CASH FLOW INFORMATION 4 5 DEFINITIONS 6 9 Cash and cash equivalents 7 9 PRESENTATION OF

More information

CREDIBLE RELIABLE CONNECTED

CREDIBLE RELIABLE CONNECTED CYPRUS 2 CREDIBLE RELIABLE CONNECTED ALTER DOMUS Cyprus 3 ALTER DOMUS Alter Domus is a leading European provider of Fund and Corporate Services, dedicated to international private equity & infrastructure

More information

TAXATION AND FOREIGN EXCHANGE

TAXATION AND FOREIGN EXCHANGE TAXATION OF EQUITY HOLDERS The following is a summary of certain PRC and Hong Kong tax consequences of the ownership of H Shares by an investor that purchases such H Shares in the Global Offering and holds

More information

Cyprus in International Tax Planning

Cyprus in International Tax Planning Seize the advantage of our expertise Technical Report This publication should be used as a source of general information only. It is not intended to give a definitive statement of the law. For the specific

More information

Annual International Bar Association Conference 2014. Tokyo, Japan. Recent Developments in International Taxation. Portugal. Guilherme Figueiredo

Annual International Bar Association Conference 2014. Tokyo, Japan. Recent Developments in International Taxation. Portugal. Guilherme Figueiredo Annual International Bar Association Conference 2014 Tokyo, Japan Recent Developments in International Taxation Portugal Guilherme Figueiredo Eurofin Capital S.A. gfigueiredo@eurofincapital.com 1. RECENT

More information

UAE Offshore Company Formation

UAE Offshore Company Formation UAE Offshore Company Formation Expanding and shifting your business activity through a UAE Offshore Company set up The Emirate of Ras Al Khaimah (RAK) has launched an offshore facility - The second in

More information

Monaco Corporate Taxation

Monaco Corporate Taxation Introduction Monaco is a sovereign principality. France is a guarantor of the sovereignty and territorial integrity of Monaco, while Monaco is to conform to French interests. Although the Prince is the

More information

Comparison table of Luxembourg investment vehicles. Chevalier & Sciales

Comparison table of Luxembourg investment vehicles. Chevalier & Sciales Comparison table of Luxembourg investment vehicles Chevalier & Sciales The purpose of this memorandum is to set out the different investment vehicles (regulated, lightly regulated and unregulated) that

More information

Statement of Cash Flows

Statement of Cash Flows HKAS 7 Revised February November 2014 Hong Kong Accounting Standard 7 Statement of Cash Flows HKAS 7 COPYRIGHT Copyright 2014 Hong Kong Institute of Certified Public Accountants This Hong Kong Financial

More information

State of Israel. Income Tax Reform. Tal Yaron-Eldar, Adv. Income Tax and Real Property Tax Commissioner

State of Israel. Income Tax Reform. Tal Yaron-Eldar, Adv. Income Tax and Real Property Tax Commissioner State of Israel Income Tax Reform Tal Yaron-Eldar, Adv. Income Tax and Real Property Tax Commissioner Starting 1/1/2003 Please notice, The following review (written in a presentation format) is a general

More information

CYPRUS: An Aviation Finance & Leasing Jurisdiction

CYPRUS: An Aviation Finance & Leasing Jurisdiction September, 2015 CYPRUS: An Aviation Finance & Leasing Jurisdiction Introduction Whilst there are many jurisdictions that are considered to be the jurisdictions of choice in the area of aviation finance

More information

IE Singapore iadvisory Seminar Doing Business in Japan: General Overview of Taxation in Japan

IE Singapore iadvisory Seminar Doing Business in Japan: General Overview of Taxation in Japan IE Singapore iadvisory Seminar Doing Business in Japan: General Overview of Taxation in Japan KPMG Tax Corporation March 12, 2013 Overview of Japanese tax (1/4) In general, a high tax jurisdiction Primary

More information

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax

USA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax USA Taxation FUNDS AND FUND MANAGEMENT 2010 3.1 Taxation of funds Taxation of regulated investment companies: income tax Investment companies in the United States (US) are structured either as openend

More information

DESCRIPTION OF THE PLAN

DESCRIPTION OF THE PLAN DESCRIPTION OF THE PLAN PURPOSE 1. What is the purpose of the Plan? The purpose of the Plan is to provide eligible record owners of common stock of the Company with a simple and convenient means of investing

More information

Lecturer: Tal Yaron-Eldar,Adv. Income Tax and Real Property Tax Commissioner starting: 1/1/2003

Lecturer: Tal Yaron-Eldar,Adv. Income Tax and Real Property Tax Commissioner starting: 1/1/2003 Lecturer: Tal Yaron-Eldar,Adv. Income Tax and Real Property Tax Commissioner starting: 1/1/2003 Please notice, The following presentation is a general overview of the reform in Israel. This synopsis does

More information

The Government of Republic of India and the Government of The Republic of Cyprus (hereinafter referred to as the Contracting Parties );

The Government of Republic of India and the Government of The Republic of Cyprus (hereinafter referred to as the Contracting Parties ); AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF INDIA AND THE GOVERNMENT OF REPUBLIC OF CYPRUS FOR THE MUTUAL PROMOTION AND PROTECTION OF INVESTMENTS The Government of Republic of India and the Government

More information

REGULATORY OVERVIEW. PRC Laws and Regulations Relating to the Product Liability

REGULATORY OVERVIEW. PRC Laws and Regulations Relating to the Product Liability Although our Company was incorporated in the Cayman Islands, a substantial part of our Group s operations are conducted in the PRC and are governed by PRC Laws and Regulations. This section sets out summaries

More information

14. Corporate Tax and Depreciation

14. Corporate Tax and Depreciation 14. Corporate Tax and Depreciation Corporate income tax is levied on income from the worldwide operations of Czech tax residents and on Czech-source income of Czech tax non-residents. Czech tax residents

More information

Taiwan e-tax Alert. Issue 37 April 7, 2014

Taiwan e-tax Alert. Issue 37 April 7, 2014 Taiwan e-tax Alert Issue 37 April 7, 2014 Views on possible applications of cross-strait taxation agreement from experience of tax treaties between Taiwan and other countries As the cross-strait taxation

More information

Guidance for companies, trusts and partnerships on completing a self-certification form

Guidance for companies, trusts and partnerships on completing a self-certification form Guidance for companies, trusts and partnerships on completing a self-certification form In order to combat tax evasion by both individuals and businesses, the UK and many other countries have entered into

More information

Corporate tax relief in Switzerland. Edition 2008

Corporate tax relief in Switzerland. Edition 2008 Corporate tax relief in Switzerland Edition 2008 Contents 3 Introduction Taxes in Switzerland 4 1. Qualifying Dividends and Capital gains 5 2. Newly established companies (tax holiday) 6 3. Holding companies

More information

The Practical Aspects of Setting Up a Business in Hong Kong. John Ashwood Managing Director Vistra (Hong Kong)

The Practical Aspects of Setting Up a Business in Hong Kong. John Ashwood Managing Director Vistra (Hong Kong) The Practical Aspects of Setting Up a Business in Hong Kong John Ashwood Managing Director Vistra (Hong Kong) Breda May, 2012 Options for setting-up a business in HK: Limited company Branch of a foreign

More information

Sri Lanka Accounting Standard-LKAS 7. Statement of Cash Flows

Sri Lanka Accounting Standard-LKAS 7. Statement of Cash Flows Sri Lanka Accounting Standard-LKAS 7 Statement of Cash Flows CONTENTS SRI LANKA ACCOUNTING STANDARD-LKAS 7 STATEMENT OF CASH FLOWS paragraphs OBJECTIVE SCOPE 1 3 BENEFITS OF CASH FLOW INFORMATION 4 5 DEFINITIONS

More information

COMPANY ANNOUNCEMENT

COMPANY ANNOUNCEMENT Bank of Valletta p.l.c. OFFICE OF THE COMPANY SECRETARY 58, Zachary Street, Valletta VLT 1130 - Malta Telephone: (356) 2275 3032, 2275 3231 Fax: (356) 2275 3711 BOV/161 COMPANY ANNOUNCEMENT The following

More information

United States Corporate Income Tax Summary

United States Corporate Income Tax Summary United States Corporate Income Tax Summary SECTION 1: AT A GLANCE CliftonLarsonAllen LLP 222 Main Street, PO Box 1347 Racine, WI 53401 262-637-9351 fax 262-637-0734 www.cliftonlarsonallen.com Corporate

More information

FOREIGNERS DOING BUSINESS IN THE UNITED STATES U.S. Taxation Overview

FOREIGNERS DOING BUSINESS IN THE UNITED STATES U.S. Taxation Overview FOREIGNERS DOING BUSINESS IN THE UNITED STATES U.S. Taxation Overview The U.S. economic activities of foreign individuals and entities are classified as inbound transactions while the foreign economic

More information

Setting up your Business in Turkey Issues to consider

Setting up your Business in Turkey Issues to consider Turkey is located as a bridge between two continents and in close proximity to Europe, the Middle East and the Caucasus. The proximity to the Balkans and the rest of Europe as well as to the growing emerging

More information

Statement of Cash Flows

Statement of Cash Flows STATUTORY BOARD FINANCIAL REPORTING STANDARD SB-FRS 7 Statement of Cash Flows This version of SB-FRS 7 does not include amendments that are effective for annual periods beginning after 1 January 2014.

More information

EXPLANATORY NOTES ON THE CRITICAL TAX ISSUES FOR THE OPERATION OF BANK HOLDING COMPANY STRUCTURE IN NIGERIA

EXPLANATORY NOTES ON THE CRITICAL TAX ISSUES FOR THE OPERATION OF BANK HOLDING COMPANY STRUCTURE IN NIGERIA NIGERIA INFORMATION CIRCULAR Published: April, 2012 Subject: EXPLANATORY NOTES ON THE CRITICAL TAX ISSUES FOR THE OPERATION OF BANK HOLDING COMPANY STRUCTURE IN NIGERIA This circular is made to address

More information

Updated Regulations regarding Withholding Tax in China

Updated Regulations regarding Withholding Tax in China Updated Regulations regarding Withholding Tax in China Fiona Fan Director, Accounting Services NCO China Oct 13, 2010 Agenda Key concepts and regulations about withholding tax in China Relationship between

More information