The end of 2012 marks a great success for Cyprus. The official
removal of Cyprus will take place on 1st January 2013. The amended
blacklist of the Russian Ministry of Finance has been published on
31 October 2012. The Republic of Cyprus was not present on that
list. The removal of Cyprus from the Russian black list has a great
meaning for Cyprus. It allows Cyprus to freely present itself to
the Russian market for outbound investments. Using the tax
beneficial Cypriot legal entities for the purpose of investing and
pay dividends back into Russia, can now occur without any
obstacles.
The structure below shows how a Cypriot legal entity can now be
used after Cyprus has been removed from the Russian black list.
Some countries with which Cyprus has a double tax treaty (DTT) in
place have been chosen for the structure, with the applicable
withholding tax rates (WHT) illustrated. Do note however that the
structure is used as an example and proper tax advice needs to
