It is clear that Cyprus after joining the EU recently has been an even more popular jurisdiction for registering international business companies (IBC). In an article written about Cyprus in OFC Report 2007, it has been described as a ‘rising international star’.
Apart from Russian and Ukrainian clients, there are a lot of other big companies from Europe who prefer Cyprus as a base for their enterprises. Cyprus has one of the lowest corporate tax rates in Europe (10%) and its tax system, like all its other laws, has been amended so that I complies with EU Acquis Communitaire.
Cyprus has been considered by international experts on Tax Planning as a very good choice, both for establishing a holding company and a trading company.
Nowadays, Cyprus, with its double tax agreements with about 43 countries, including the USA, by being a full member of the European Union, and by implementing various anti money laundering laws is considered to be a ‘clean’ jurisdiction with a very good reputation.
With regard to Holding Companies generally speaking, there is a full exemption from local taxation in respect of any dividends received by the company from its local and foreign subsidiaries. There is no tax on the sale of the shares of a Cyprus company in foreign subsidiaries. There is no withholding tax on outgoing dividends remitted by a Cypriot company to the ultimate parent company. Due to the existence of double tax treaties, the incoming dividends are either exempt from or are subject to low withholding taxes in the subsidiary’s jurisdiction. There is also exemption at source of interest where the beneficial owner is a non-resident. Interest expenses payable by a Cypriot company are fully deductible. A Cypriot holding company may also be capitalized with loans and the interest paid at arm’s length to the parent company will be deductible since in Cyprus, there are no specific rules on thin capitalization. Another advantage is that our Controlled Foreign Companies Legislation is relaxed and mainly targets certain types of income that does not derive from genuine business, ie. Passive income.
Cyprus is also attractive to trading companies for tax planning purposes. If the management and control of the company is situated in Cyprus, then the company is taxed 10% on its worldwide income in Cyprus. However, sometimes it might be proper to even establish the management and control of the Cyprus company outside Cyprus in a jurisdiction which only taxes income generated in its jurisdiction. In this case if the trading is taking place in jurisdictions other than Cyprus or the place where the company is permanently established, the company will not be subject to taxation in Cyprus or in the jurisdiction where it has been permanently established.
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