Cyprus Holding Companies

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Cyprus Holding Companies"

Transcription

1 Cyprus Holding Companies

2 I. Legal Framework Limited liability companies in Cyprus are regulated by Cyprus Companies Law (CAP113), which is a virtual copy of the 1948 English Companies Act and which has been fully harmonised with relevant EU legislation as part of the island s accession to the EU in CAP113 does not differentiate between holding companies and companies engaging in other activities. Furthermore, as of 1 January 2003, Cyprus tax legislation fully complies with the OECD initiative against harmful tax practices. A Cyprus tax resident company is subject to tax in Cyprus on its worldwide income, whilst a non-cyprus tax resident person is subject to tax only on incomes arising in Cyprus (subject to domestic law and or double taxation conventions exemptions). Cyprus tax resident companies are all companies whose management and control is exercised in Cyprus irrespective of their place of registration. There is no definition of the term «management and control» in the Cyprus tax law nor is there any circular on this issue from the Cyprus tax authority.

3 I. cont d The term «management and control» is found in the definition of «resident in the Republic» in section 2 of the Income Tax Law 118(I)/02, as amended. Under this definition, residence, when applied to a company, means a company whose management and control is exercised in the Republic. UK case law in this respect would be of persuasive authority. In practice it may (in simple terms) be taken to mean that management and control is: (a) where the majority of the directors reside, (b) where the board meetings of the company are held and (c) where the general policy of the company is formulated The co-existence of all three criteria is essential. The place where the meetings of the directors are held, although essential, may not in itself be conclusive sometimes. It is the place where the real management and control of a company are exercised. A company may claim that its management and control is exercised in Cyprus by declaring so on its tax return and such a declaration would be accepted by the tax authorities without any further examination. If the residency of a company is disputed by another tax authority (for example where the beneficial owner resides), the issue would be resolved under the procedure envisaged in the bilateral double taxation treaty between the two countries.

4 II. Introduction The income tax rate for Cyprusresident companies is 10%, which is the lowest in the European Union. Additionally, certain types of income may also be subject to Special Defence Contribution (SDC). The income of a holding company would normally fall under three categories: 1.Dividend income 2.Interest income 3.Trading/Capital Gain on disposal of investments 1. Dividend Income Dividend income is exempt from Income Tax. Dividends received from a non- Cyprus tax resident company are also exempt from SDC. The exemption does not apply where (1) the dividend paying company engages directly or indirectly more than 50% in activities which lead to investment income and (2) the foreign tax burden on the income of the company paying the dividends is substantially lower than the tax burden of the company in Cyprus (substantially lower means lower than 5%). If one of the conditions applies, the dividend still gets the exemption. Example 1: the dividend is paid by a company whose income is more than 50% investment income but the foreign tax burden is not substantially lower than that of Cyprus (the foreign tax is over 5%). In this example the dividend will be exempt in Cyprus. Example 2: the dividend is paid from a company whose income is more than 50% trading income and the foreign tax burden is nil. Again the dividend in this example will still be exempt in Cyprus. Example 3: the dividend is paid from a company whose income is more than 50% investment income and the foreign tax burden is substantially lower than the Cyprus tax. In this example the dividend in Cyprus will be taxable at 20% (from 1 January 2012 for two years) against which credit relief will be given in respect of any foreign tax.

5 II. 2. Interest income A Cypriot-resident holding company receiving interest which is deemed not to be from or closely related to its ordinary business activities is exempt from income tax but is subject to SDC at 10% (up to 30/8/2011) and 15% (as from 31/8/2011) on the whole amount of the interest received (see table below). In the case where the interest is considered to have been earned by a company in the ordinary course of business or interest which is closely related to the ordinary activities of the business - for example, a bank or a land developer who commonly sells land or buildings for which the settlement is made by instalments that are carrying interest, or a Cyprus company who borrows from and lends to other Group companies the interest will be subject to income tax at 10% and will be exempt from SDC. Financing activities are considered as trading activities and therefore not considered as passive investment. Consequently, interest income from such activities is exempt from SDC and is taxed as a trading income at 10% income tax only. Source of income Interest income (considered to be trading income) Interest income (investment income) Income Tax % SDC % Total tax burden % /15 10/15

6 II. 3. Trading/Capital Gain on Disposal of investments Any capital or trading gain arising from the disposal of titles is exempt from taxation. The term titles has been clarified in a recent tax circular issued in December 2008 to include the following: 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 i.e. ADRs & GDRs, rights of claim on bonds and debentures, index participations only if they result in titles, repurchase agreements or Repos on titles, participations in companies for Russian OOO & ZAO the Americans LLC provided that they suffer tax on their profits the Romanian SA & SRL the Bulgarians AD & OOD, units in open-end or close-end collective investment schemes which includes investment trusts, investment funds, mutual funds, unit trusts, real estate investment trusts, international collective investment schemes, undertakings for collective investments in transferable securities. It should be noted that any gains arising from the sale of shares of companies owning immovable property that is situated in Cyprus are subject to capital gains tax.

7 II. OTHER POINTS TO BE NOTED Taxation of dividends paid by the holding company to its shareholders Irrespective of the provisions stated in any double tax agreement in force between Cyprus and any other country, there is no withholding tax upon payment of dividends from a Cyprus company to non-cyprus tax resident shareholders. The nil withholding tax provisions are specifically provided in the local tax legislation. Utilisation of losses Tax losses incurred in any one year which cannot be set off against other profits of the same year, can be carried forward and set off against future profits for an indefinite period of time. This provision applies for all unutilized tax losses for the year 1997 and onwards. It should be noted that when the expenses are associated with income which is not taxable according to the provisions of the legislation, no losses are recognized for tax purposes i.e. expenses associated with the sale of titles.

8 II. OTHER POINTS TO BE NOTED cont d Tax ruling system The tax authorities may issue binding rulings for specific structure and facts. VAT in relation to holding companies According to the Cyprus VAT legislation, holding companies do not have taxable supplies and therefore have neither obligation nor entitlement to apply even for a voluntary registration. This means that any VAT suffered on their expenses in Cyprus or abroad cannot be recovered. Company registration fees There is a fixed fee of 102,52 plus 0.6% on the amount of the authorized share capital. Subsequent increases of the authorized share capital are subject to a capital duty of 0.6%. Shares may also be issued above their nominal value in which case the authorized share capital does not need to be increased.

9 George Karavis Tax Partner Grant Thornton Cyprus Agiou Nicolaou Street Nimeli Court Block C, Engomi, 2408 Lefkosia P.O.Box 23907, 1687 Lefkosia Cyprus T F E All rights reserved. Grant Thornton (Cyprus) Ltd is a member firm of Grant Thornton International Ltd (Grant Thornton International). References to Grant Thornton are to Grant Thornton International or its member firms. Grant Thornton International and the member firms are not a worldwide partnership. Services are delivered independently by the member firms.

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

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

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

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

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

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

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

SYLLABUS BASICS OF INTERNATIONAL TAXATION. ! States levy taxes by virtue of their sovereignty

SYLLABUS BASICS OF INTERNATIONAL TAXATION. ! States levy taxes by virtue of their sovereignty SYLLABUS BASICS OF INTERNATIONAL TAXATION! States levy taxes by virtue of their sovereignty! Tax sovereignty, however, is not unlimited. There must either be a personal or an objective connection between

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

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

Cyprus International Trusts

Cyprus International Trusts Cyprus International Trusts Cyprus International Trusts qualification criteria The International Trusts Law of 1992 complements the Trustee Law which is based on the English Trustee Act 1925. Under section

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

German Tax Facts. The Expatriate Financial Guide to Germany

German Tax Facts. The Expatriate Financial Guide to Germany The Expatriate Financial Guide to Germany German Tax Facts Introduction Tax Year Assessment Basis Income Tax Taxation in Germany occurs at a national and municipal level. The Ministry of Finance controls

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

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

SPANISH TAX REFORM: MAIN ISSUES FOR M&A AND FINANCING TRANSACTIONS DECEMBER 2014

SPANISH TAX REFORM: MAIN ISSUES FOR M&A AND FINANCING TRANSACTIONS DECEMBER 2014 TAX BRIEFING SPANISH TAX REFORM: MAIN ISSUES FOR M&A AND FINANCING TRANSACTIONS DECEMBER 2014 THIS BRIEFING FOCUSES ON THOSE MEASURES INCLUDED IN THE CIT ACT WHICH AFFECT M&A, FINANCING & REFINANCING TRANSACTIONS.

More information

Country Tax Guide. www.bakertillyinternational.com

Country Tax Guide. www.bakertillyinternational.com Country Tax Guide www.bakertillyinternational.com Baker Tilly Russia www.bakertilly.ru Eduard Kutcherov T: +7 (495) 783 88 00 kutcherov@bakertilly.ru Andrey Kirillov T: +7 (495) 783 88 00 a.kirillov@bakertilly.ru

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

CYPRUS INTERNATIONAL TRUSTS. A. THEORETICAL BACKGROUND Cyprus International Trusts very much follow the way UK trusts operate.

CYPRUS INTERNATIONAL TRUSTS. A. THEORETICAL BACKGROUND Cyprus International Trusts very much follow the way UK trusts operate. CYPRUS INTERNATIONAL TRUSTS Cypriot trust law has been shaped on the basis of UK law and the Cyprus Trustee Law Cap.193 emulates the English Trustee Act 1925. Concerning the current Cyprus legislative

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

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

The positioning of Cyprus as a leading international business centre has been

The positioning of Cyprus as a leading international business centre has been European directive helps The incorporation into local law of the EU merger directive has created the possibility of tax-neutral international mergers using, explains Sophie Stylianou of Eurofast Taxand

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

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

Investing into India through Mauritius

Investing into India through Mauritius BERMUDA BRITISH VIRGIN ISLANDS CAYMAN ISLANDS CYPRUS DUBAI HONG KONG LONDON MAURITIUS MOSCOW SÃO PAULO SINGAPORE conyersdill.com July 2010 Investing into India through Mauritius Mauritius Funds Mauritius

More information

WLP LAW. II. The Dutch corporate tax system. INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013

WLP LAW. II. The Dutch corporate tax system. INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013 INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013 i Tel +31 I. (0)88 Introduction 2001300 Cell +31 (0)6 M The Netherlands is an attractive and advantageous

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

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

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

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE EN EN EN EUROPEAN COMMISSION Brussels, COM(2010) COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Removing cross-border tax obstacles

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

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

Greece New Tax Laws Aim to Raise More Revenue. Law No. 4110. In This Issue: March 4, 2013 2013-041

Greece New Tax Laws Aim to Raise More Revenue. Law No. 4110. In This Issue: March 4, 2013 2013-041 flash International Executive Alert A Publication for Global Mobility and Tax Professionals by KPMG s International Executive Services Practice Greece New Tax Laws Aim to Raise More Revenue by Georgia

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

Self managed superannuation funds investment strategy and investment restrictions

Self managed superannuation funds investment strategy and investment restrictions Self managed superannuation funds investment strategy and investment restrictions Investment management is a key area of responsibility for trustees of self managed superannuation funds (SMSFs). The Superannuation

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

The marketing of participations in foreign private equity funds from an Austrian tax perspective

The marketing of participations in foreign private equity funds from an Austrian tax perspective Seite 1 von 6 www.altassets.net The case for countries - Austria The marketing of participations in foreign private equity funds from an Austrian tax perspective Gerald Gahleitner, Gerald Toifl, Leitner

More information

Taxation of Cross-Border Mergers and Acquisitions

Taxation of Cross-Border Mergers and Acquisitions KPMG INTERNATIONAL Taxation of Cross-Border Mergers and Acquisitions Panama kpmg.com 2 Panama: Taxation of Cross-Border Mergers and Acquisitions Panama Introduction The signing of several Free Trade Agreements

More information

Tax Treatment of Stocklending/Sale and Repurchase (repo) Transactions

Tax Treatment of Stocklending/Sale and Repurchase (repo) Transactions Tax Treatment of Stocklending/Sale and Repurchase (repo) Transactions 4.6.13 1. Background The purpose of this manual is to set out a tax treatment, which may be followed for the purposes of corporation

More information

Financial Services Guide

Financial Services Guide Financial Services Guide 1. The Purpose of This Financial Services Guide This Financial Services Guide ( FSG ) is an important document. Please read it carefully and ensure that you understand it. Azure

More information

ishares IV Public Limited Company

ishares IV Public Limited Company ishares IV Public Limited Company (An umbrella investment company with variable capital and having segregated liability between its Funds incorporated with limited liability in Ireland under registration

More information

Iberdrola, S.A. Scrip Dividend Scheme Information Booklet July 2015. June 2015

Iberdrola, S.A. Scrip Dividend Scheme Information Booklet July 2015. June 2015 Iberdrola, S.A. Scrip Dividend Scheme Information Booklet July 2015 June 2015 Dear shareholder, The 2015 Annual General Shareholders Meeting of Iberdrola, S.A. ( Iberdrola ) approved the continued offer

More information

Investing in Northern Ireland

Investing in Northern Ireland Investing in Northern Ireland Key Tax Issues August 2012 kpmg.ie 1 1 Contents 1 Introduction 3 2 Corporation tax 4 3 Individual taxation 10 4 Other taxes 12 Appendix 1 - UK Tax Residence 13 2 1. Introduction

More information

Setting up your Business in SINGAPORE Issues to consider

Setting up your Business in SINGAPORE Issues to consider SINGAPORE is commerce, industry, heritage, culture and entertainment all rolled into a little island of slightly over 700 square kilometres with a population of 5.4 million. Here at the crossroads of Asia,

More information

Action: Notice of an application for an order pursuant to: (a) section 6(c) of the Investment

Action: Notice of an application for an order pursuant to: (a) section 6(c) of the Investment SECURITIES AND EXCHANGE COMMISSION [Investment Company Act Release No. IC-32163; File No. 812-14523] MainStay Funds Trust, et al.; Notice of Application June 27, 2016 Agency: Securities and Exchange Commission

More information

United Kingdom Taxation

United Kingdom Taxation United Kingdom Taxation FUNDS AND FUND MANAGEMENT 2010 3.1 Taxation of funds Authorized open-ended mutual funds in the United Kingdom are organized as authorized unit trusts (AUTs) or open-ended investment

More information

Shares Mutual funds Structured bonds Bonds Cash money, deposits

Shares Mutual funds Structured bonds Bonds Cash money, deposits FINANCIAL INSTRUMENTS AND RELATED RISKS This description of investment risks is intended for you. The professionals of AB bank Finasta have strived to understandably introduce you the main financial instruments

More information

Provinces and territories also impose income taxes on individuals in addition to federal taxes

Provinces and territories also impose income taxes on individuals in addition to federal taxes Worldwide personal tax guide 2013 2014 Canada Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Canada Revenue Agency (CRA)

More information

A company is tax resident in Cyprus if it is managed and controlled in Cyprus.

A company is tax resident in Cyprus if it is managed and controlled in Cyprus. CORPORATE TAX IN CYPRUS CORPORATE INCOME TAX Tax residency A company is tax resident in Cyprus if it is managed and controlled in Cyprus. Where a company is tax resident in Cyprus, tax is imposed on income

More information

15 Double Taxation Relief

15 Double Taxation Relief 15 Double Taxation Relief 15.1 Concept of Double Taxation Relief In the present era of cross-border transactions across the globe, the effect of taxation is one of the important considerations for any

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

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

Corporate taxation and asset depreciation rules are described in the Fact Sheet on Corporate Tax and Depreciation.

Corporate taxation and asset depreciation rules are described in the Fact Sheet on Corporate Tax and Depreciation. 13. Taxation The system of taxation described below is derived from the Czech tax legislation and may be modified by a particular Double Taxation Treaty. The current tax system was introduced in January

More information

p r o v i d i n g c o n f i d e n c e t h r o u g h p e r f o r m a n c e

p r o v i d i n g c o n f i d e n c e t h r o u g h p e r f o r m a n c e Hong Kong Services p r o v i d i n g c o n f i d e n c e t h r o u g h p e r f o r m a n c e HOW TRIDENT TRUST CAN ASSIST YOU IN HONG KONG Trident Trust has had a multilingual presence in Hong Kong for

More information

Implementation of the EU tax directives in Poland

Implementation of the EU tax directives in Poland Bartosz Bacia Implementation of the EU tax directives in Poland Since Poland joined the EU on May 1 2004, Polish tax law need to be adapted to the EU Council directives for the member states. The new legal

More information

Lord Abbett Family of Funds and Lord, Abbett & Co. LLC; Notice of Application. AGENCY: Securities and Exchange Commission ( Commission ).

Lord Abbett Family of Funds and Lord, Abbett & Co. LLC; Notice of Application. AGENCY: Securities and Exchange Commission ( Commission ). This document is scheduled to be published in the Federal Register on 07/07/2016 and available online at http://federalregister.gov/a/2016-16038, and on FDsys.gov 8011-01p SECURITIES AND EXCHANGE COMMISSION

More information

TAXATION INFORMATION. Purchases of Ordinary Shares by the Mondi Incentive Schemes Trust Trustees

TAXATION INFORMATION. Purchases of Ordinary Shares by the Mondi Incentive Schemes Trust Trustees TAXATION INFORMATION South African taxation The following is a general summary of the South African tax implications for Ordinary Shares held by South African tax residents included in the Odd-lot Offer,

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

Retirement Annuity Contract & Self-Invested Personal Pension ( SIPP ) Company. Guidance Notes & Key Features

Retirement Annuity Contract & Self-Invested Personal Pension ( SIPP ) Company. Guidance Notes & Key Features Retirement Annuity Contract & Self-Invested Personal Pension ( SIPP ) Company Guidance Notes & Key Features Background The Income Tax (Jersey) Law 1961 allows individuals to look after their own pension

More information

ANNEX B-2: Research and Development (R&D) Tax Measures

ANNEX B-2: Research and Development (R&D) Tax Measures ANNEX B-2: Research and Development (R&D) Tax Measures 1) Liberalisation of R&D Tax Deduction a) Enhanced deduction for R&D expenses Existing Tax Treatment Currently, taxpayers carrying on a manufacturing

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

55 Amendment of section 1 (interpretation) of the VAT Act 1972

55 Amendment of section 1 (interpretation) of the VAT Act 1972 54 Interpretation (Part 3) This section contains definitions of the legal citations used in Part 3. This is a conventional provision in Finance Acts. It allows abbreviated terms to be used in reference

More information

Company Taxation. There is no difference in treatment in determining the profits and income from any source of a company.

Company Taxation. There is no difference in treatment in determining the profits and income from any source of a company. Company Taxation There is no difference in treatment in determining the profits and income from any source of a company. 1 Calculation of a tax payable for a company 1. Tax on Income taxable at special

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

China Tax Newsletter. January 2014

China Tax Newsletter. January 2014 BDO China Shu Lun Pan Certified Public Accountants LLP LIXIN Certified Tax Agents Co., Ltd China Tax Newsletter Our tax newsletter for this month covers: 1. Goods Meeting Certain Requirements that Are

More information

NORTHERN BLIZZARD RESOURCES INC. STOCK DIVIDEND PROGRAM

NORTHERN BLIZZARD RESOURCES INC. STOCK DIVIDEND PROGRAM NORTHERN BLIZZARD RESOURCES INC. STOCK DIVIDEND PROGRAM Introduction This Stock Dividend Program (the "Program") provides eligible holders ("Shareholders") of common shares ("Common Shares") of Northern

More information

Worldwide personal tax guide 2013 2014. Japan. Local information. 2013 National Income Tax Rates Taxable Income Band National Income Tax Rates

Worldwide personal tax guide 2013 2014. Japan. Local information. 2013 National Income Tax Rates Taxable Income Band National Income Tax Rates Worldwide personal tax guide 2013 2014 Japan Local information Tax Authority Ministry of Finance Website www.mof.go.jp Tax Year 1 January to 31 December Tax Return due date 15 March Is joint filing possible

More information

Chapter 1 Legislative Background and Tax Reform

Chapter 1 Legislative Background and Tax Reform Chapter 1 Legislative Background and Tax Reform The Chinese tax system has recently developed closely to the economic growth of the country. The entry of China into the World Trade Organization (WTO) and

More information

Tax Facts & Figures 2014 - Cyprus

Tax Facts & Figures 2014 - Cyprus www.pwc.com.cy Tax Facts & Figures 2014 - Cyprus The tax system in Cyprus January 2014 Table of contents Foreword 1 Personal income tax 2 Special contribution 10 Corporation tax 12 Special contribution

More information

LLC Deutsche Bank and UFGIS Holding (Cyprus) Limited Combined Financial Statements for the year ended 31 December 2008

LLC Deutsche Bank and UFGIS Holding (Cyprus) Limited Combined Financial Statements for the year ended 31 December 2008 LLC Deutsche Bank and UFGIS Holding (Cyprus) Limited Combined Financial Statements for the year ended 31 December 2008 Contents Independent Auditors Report... 3 Combined Income Statement... 4 Combined

More information

Introduction. Losses which may be group relieved

Introduction. Losses which may be group relieved Corporation tax losses how relief can be obtained By: Claire Scott McAteer, BSc, MSc Advanced Accounting, ACA, AITI, CTA, Examiner in Professional 2 Advanced Taxation and Niall McAteer, BSc, PGDip Advanced

More information

Trusts and settlements income treated as the settlor's

Trusts and settlements income treated as the settlor's Helpsheet 270 Tax year 6 April 2012 to 5 April 2013 A Contacts Please phone: the number printed on page TR 1 of your tax return the SA Helpline on 0845 9000 444 the SA Orderline on 0845 9000 404 for helpsheets

More information

Tax Guide for Individuals Moving to the UK

Tax Guide for Individuals Moving to the UK Tax administration and allowances The UK taxing authority is known as Her Majesty s Revenue and Customs (or HMRC for short) and the tax year runs from 6 April to the following 5 April. There is no system

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

Bosera ETFs. Bosera FTSE China A50 Index ETF

Bosera ETFs. Bosera FTSE China A50 Index ETF Important: If you are in any doubt about the contents of this Addendum, you should consult your stockbroker, bank manager, solicitor, accountant or other financial adviser. This Addendum forms an integral

More information

GENERAL OVERVIEW OF TAXES, LEVIED IN UKRAINE

GENERAL OVERVIEW OF TAXES, LEVIED IN UKRAINE GENERAL OVERVIEW OF TAXES, LEVIED IN UKRAINE General information on the tax system of Ukraine For the purposes of further discussion we feel it appropriate to provide first brief overview of the tax system

More information

Cyprus Tax Facts 2013

Cyprus Tax Facts 2013 Cyprus Tax Facts 2013 The present Grant Thornton publication aims to provide the reader with an overview and a quick reference guide to the Cyprus tax system. The information contained in this publication

More information

The ConocoPhillips Share Incentive Plan EXPLANATORY BOOKLET

The ConocoPhillips Share Incentive Plan EXPLANATORY BOOKLET The ConocoPhillips Share Incentive Plan EXPLANATORY BOOKLET September 2014 Contents Page 1. Introduction 1 2. Summary of how the Plan works 2 3. Eligibility and joining the Plan 4 4. Shares of Common Stock

More information

Related party transactions Section 34D has been enacted recently in the SITA to legislatively endorse the arm slength

Related party transactions Section 34D has been enacted recently in the SITA to legislatively endorse the arm slength 65. Singapore Introduction Although Singapore s income tax rates are traditionally lower than the income tax rates of the majority of Singapore s primary trading partners, the Inland Revenue Authority

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

APPENDIX FOR U.S. SECURITIES TRADING

APPENDIX FOR U.S. SECURITIES TRADING APPENDIX FOR U.S. SECURITIES TRADING This Appendix applies in respect of securities trading services in U.S. Securities provided by ICBCIS to the Client. In the event that there is any inconsistency between

More information

Overseas aspects of corporation tax may be examined as part of question two, or it could be examined in questions four or five.

Overseas aspects of corporation tax may be examined as part of question two, or it could be examined in questions four or five. RELEVANT TO ACCA QUALIFICATION PAPER F6 (UK) Overseas aspects of corporation tax This article is relevant to candidates taking Paper F6 (UK) in either June or December 2013, and is based on tax legislation

More information

Yi Liu, Run Ming Law Office. China s Legal System and Corporate Aircraft

Yi Liu, Run Ming Law Office. China s Legal System and Corporate Aircraft Yi Liu, Run Ming Law Office China s Legal System and Corporate Aircraft I. Chinese Regulatory Scheme relating to Aircraft Purchase, Finance & Leasing Import Approval - National Development and Reform Commission

More information

The Expatriate Financial Guide to

The Expatriate Financial Guide to The Expatriate Financial Guide to Australian Tax Facts Australia Introduction Tax Year Assessment Basis Income Tax Taxation in Australia is mostly at a national/federal level with property taxes (council

More information

tax update October 2014

tax update October 2014 tax update October 2014 Summary Luxembourg news 3 Luxembourg budget 2015 3 Luxembourg-France Double Tax Treaty amended: capital gains on the disposal of shares in companies ultimately invested in French

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

DOING BUSINESS IN SWEDEN

DOING BUSINESS IN SWEDEN DOING BUSINESS IN SWEDEN CONTENTS 1 Introduction 3 2 Business environment 4 3 Foreign Investment 7 4 Setting up a Business 9 5 Labour 12 6 Taxation 14 7 Accounting & reporting 17 8 UHY Representation in

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

Having amended the Convention by an Additional Protocol that Modifies the Convention, signed at Mexico City on September 8, 1994;

Having amended the Convention by an Additional Protocol that Modifies the Convention, signed at Mexico City on September 8, 1994; SECOND ADDITIONAL PROTOCOL THAT MODIFIES THE CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE UNITED MEXICAN STATES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE

More information

Tax. Pinhas Rubin, Daniel Paserman /29/

Tax. Pinhas Rubin, Daniel Paserman /29/ Tax Gornitzky & Co. Pinhas Rubin, Daniel Paserman /29/ Trends in Israeli Tax Law Change of a Business Model - International Acquisitions of Israeli Hi-Tech Companies International corporations are extremely

More information

Notes on the parent company financial statements

Notes on the parent company financial statements 316 Financial statements Prudential plc Annual Report 2012 Notes on the parent company financial statements 1 Nature of operations Prudential plc (the Company) is a parent holding company. The Company

More information

Online Investments. Our Fund Range and Investments

Online Investments. Our Fund Range and Investments Online Investments Our Fund Range and Investments Why is it important to read this document? This document explains the funds available for you to invest in through our Investment ISA, which is a Stocks

More information

trust and corporate services in Gibraltar

trust and corporate services in Gibraltar Acquarius Trust Group trust and corporate services in Gibraltar Comprehensive Global Fiduciary Services.the total solution built around you the people the service the quality Acquarius Trust Group 1 OUR

More information

FAQs on Cost-Basis Reporting for Brokers

FAQs on Cost-Basis Reporting for Brokers FAQs on Cost-Basis Reporting for Brokers The IRS published a list of Frequently Asked Questions on the new expanded tax reporting requirement for brokers which include reporting their customer s tax basis

More information

Common Working Theory into Practice

Common Working Theory into Practice Common Working Theory into Practice European Conference Warsaw, July 2010 Peter Karl Plattner Real property - Italy Real property Italy Acquisition of real property general considerations Acquisition of

More information

tes for Guidance Taxes Consolidation Act 1997 Finance Act 2014 Edition - Part 13

tes for Guidance Taxes Consolidation Act 1997 Finance Act 2014 Edition - Part 13 Part 13 Close companies CHAPTER 1 Interpretation and general 430 Meaning of close company 431 Certain companies with quoted shares not to be close companies 432 Meaning of associated company and control

More information

Share redemption 2016

Share redemption 2016 Share redemption 2016 Information for shareholders in HiQ International AB (publ) regarding the Board s proposal for a share split and mandatory redemption procedure Background BACKGROUND HiQ International

More information

Country Tax Guide. www.bakertillyinternational.com

Country Tax Guide. www.bakertillyinternational.com www.bakertillyinternational.com International Tax Contact Moscow Andrey Kirillov T: +7 (495) 783 88 00 a.kirillov@bakertillyrussaudit.ru Corporate Income Taxes Resident companies, defined as those which

More information

In accordance with Listing Rule 12.10, Computershare Limited attaches its updated Share Trading Policy.

In accordance with Listing Rule 12.10, Computershare Limited attaches its updated Share Trading Policy. MARKET ANNOUNCEMENT Computershare Limited ABN 71 005 485 825 Yarra Falls, 452 Johnston Street Abbotsford Victoria 3067 Australia PO Box 103 Abbotsford Victoria 3067 Australia Telephone 61 3 9415 5000 Facsimile

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