HEADQUARTERING AND BUSINESS RELOCATION TO CYPRUS
INTRODUCTION By now everybody knows that Cyprus belongs to the EU, about our unrivalled sunny days and our strategic location. This is old news. Why bring Cyprus back on the Headquartering map? Does Cyprus have something new to offer to businesses and individuals that wish to relocate their businesses to Cyprus?
The Third Anti-Tax Avoidance Directive (ATAD 3) The tombstone of shell entities
A. INTRODUCTION The European Commission on the 22nd of December 2021 published a legislative proposal for a Directive to be issued, the Third Anti-Tax Avoidance Directive, known as “ATAD 3”, which sets forth rules to prevent the misuse of shell companies for tax purposes. The Directive should be adopted early 2022 by the Council and …
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DAC6 and Hallmark E1 Use of unilateral safe harbour rules in Cyprus
The purpose of this tax bulletin is to shed some light on the use of unilateral safe harbour rules in Cyprus and specifically as to when an arrangement becomes reportable for DAC6 purposes for meeting the requirements of Hallmark E1.
The Management and Control Test: Taxation of Cyprus and Foreign Companies
INTRODUCTION With this publication, we shall explore the notion of management and control as this is applicable in Cyprus and affects the taxation of Cyprus and Overseas companies.
The Defence of Illegality – “Ex turpi causa non oritur actio” – The Cyprus Approach
HISTORICAL BACKGROUND There is a long-standing common law principle, that the courts will not assist a party whose case is based upon an immoral or illegal act.
EXPRESS TRUSTS: THE REGISTER FOR BENEFICIARIES
INTRODUCTION On the 18th of June 2021, the Cyprus Securities and Exchange Commission (the “CySec”) pursuant to Article 61C of the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2021 (the “AML Law”) issued a regulation (Regulatory Administrative Act 257/2021) (the “Directive”), identifying the obligations and procedure for the registration, notification, administration, …
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COMMENCEMENT OF THE BENEFICIAL OWNERS REGISTER WITH THE REGISTRAR OF COMPANIES
INTRODUCTION On the 12th of March 2021, the Registrar of Companies and Official Receiver (the “Registrar”) pursuant to Article 61A of the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2021 (the “AML Law”) issued a regulation (Regulatory Administrative Act 112/2021) (the “Directive”), identifying the obligations, methodology and procedure companies and legal …
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CYPRUS – THE REGISTERS FOR REAL BENEFICIARIES (Companies – Trusts and other Legal Bodies)
A. INTRODUCTION On 18/02/2021 the Cyprus House of Representatives has enacted the amending law on the Prevention and Suppression of Money laundering and Terrorist Financing Law of 2021 (the “AML Law”) transposing at a national level the 5th Anti-Money Laundering EU Directive 2018/843 (the “AMLD”) which imposes minimum standards to the Member States for the …
CYPRUS AND DAC6
INTRODUCTION The Directive (EU) 2018/822 expand once more the provisions of the Directive 2011/16/EU – Directive on Administrative Cooperation (DAC), regarding mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements. The Directive (EU) 2018/822 represents the 6th modification of DAC, and for this purpose it is called DAC6. …
CYPRUS – THE TAX TREATMENT OF INTEREST
A. INTRODUCTION With this publication we outline the main provisions of the Taxation Laws in relation to the tax treatment of interest income and interest expense and we elaborate on the various financing schemes available. B. THE BASIS OF TAXATION OF INTEREST INCOME Generally, the Taxation Laws in Cyprus are applicable only to tax residents …