Popular Tax Structures

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1 Popular Tax Structures

2 Popular Structures: Holding Structure Low or even zero Tax Withheld (WHT) on Dividends paid to the Holding No taxation on capital gains from selling the shares of the foreign subsidiary company No taxation in on income from dividends and trading 0% Tax Withheld (WHT) on dividends paid from to the company 0% WHT on Dividends Holding Low or even zero WHT on Dividends Zero tax on dividends and capital gains In the case of an EU based foreign subsidiary company, this structure can provide a tax free exit of dividends from the EU

3 Popular Structures: Financing Structure Interest deduction at the level of the foreign subsidiary company, therefore, decreasing its profit Low or even zero tax withheld (WHT) on interest paid to the Financing Interest deduction at the level of the Financing, therefore, leaving a small profit margin that can be as low as 0.125% which will be subject to 12.5% corporation tax after deducting expenses and any tax already withheld abroad on the interest paid to the company Zero tax withheld (WHT) on interest paid from to the. Small margin taxed at 12.5% Zero WHT on Interest Financing Low or even zero WHT on interest Loan Loan

4 Popular Structures: Intellectual Property Structure Tax deductibility of the royalty payments at the level of the foreign subsidiary, therefore, decreasing its profits Low or even zero tax withheld (WHT) on royalty payments Tax deductibility of the royalty payments at the level of, therefore, leaving a small profit margin which will be subject to 12.5% corporation tax after deducting expenses and any tax already withheld abroad on the royalties received Under the new Law regarding Intellectual Property 80% of such income is tax free, therefore, only the 20% of the IP income is subject to the 12.5% corporation tax provided that the company is the owner of the IP rights. In the example of the diagram this does not apply because the owner of the IP rights is the. Small margin taxed at 12.5% Low or even zero WHT on royalties Low or even zero WHT on royalties IP License License

5 Popular Structures: Special Purpose Vehicle 0% WHT Zero or low tax withheld (WHT) on dividends paid to the No taxation in on dividend income, on profit s from trading and capital gains Interest received in not arising from the ordinary activities of the company is exempt from corporation tax Interest received in arising from the ordinary activities of the company will be subject to 10% corporation tax after tax allowable expenses and foreign tax credits No tax withheld (WHT) in for dividends paid to the Shares SPV Bonds Zero or low WHT on dividends GDRs No taxation on income from dividends & trading Other Titles

6 Popular Structures: Collective Investment Schemes (Private Funds) Investors Zero or low WHT on dividends paid to the No taxation in on capital gains from selling the Investments, on dividend and on trading income Interest received in not arising from the ordinary activities of the company is exempt from corporation tax Interest received in arising from the ordinary activities of the company will be subject to 12.5% corporation tax after tax allowable expenses and foreign tax credits No tax withheld (WHT) in for dividends paid to the foreign investors No taxation on income from dividends, trading and capital gains Dividends 0% WHT Zero or low WHT on dividends CIS Investments

7 Popular Structures: Structures (1) Low or even zero tax withheld (WHT) on dividends paid to the No taxation in, and in many cases at the level of the foreign subsidiary (*), on capital gains from selling the shares of the foreign subsidiary companies No taxation in on dividend and trading income Comp. Comp. 0% WHT on dividends Zero or low WHT on dividends Comp. No taxation on capital gains, dividends & trading Comp. No tax withheld (WHT) in for dividends paid to the foreign company (*) If capital gains tax at the level of the foreign subsidiary is an issue please see example 2

8 Popular Structures: Structures (2) As before but this structure offers more flexibility as the parent company can sell its subsidiaries without any tax complications Zero WHT on dividends No taxation on capital gains, dividends & trading Zero WHT on dividends Low or even zero WHT on dividends No taxation on capital gains, dividends & trading

9 Popular Structures: Consulting The net profit, and therefore the tax burden, of the is decreased as it purchases services from the consulting company Part of the total profit is transferred to the which benefits from low Corporation Tax (12.5%) No tax withheld (WHT) in for dividends paid to the foreign company Profits taxed at 12.5% Consulting 0% WHT on dividends Sale of Services (at a profit)

10 Popular Structures: Triangular Trading (Imports) The net profit, and therefore the tax burden, of the Trading is decreased as it purchases goods from the company at increased prices Profits taxed at 12.5% Trading 0% WHT on dividends Sale of Goods (at a profit) Part of the total profit is transferred to the which benefits from low Corporation Tax (12.5%) No tax withheld (WHT) in for dividends paid to the foreign company Purchase of Goods Trading Retail

11 Popular Structures: Triangular Trading (Exports) The net profit, and therefore the tax burden, of the Manufacturing is decreased as it sells goods to the company at reduced prices Manufacturing Sale of Goods 0% WHT on dividends Part of the total profit is transferred to the which benefits from low Corporation Tax (12.5%) No tax withheld (WHT) in for dividends paid to the foreign company Profits taxed at 12.5% Export of Goods (at a profit)

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