Relocation to Cyprus Finding a suitable tax friendly jurisdiction The Issue Our client, an EU citizen high net worth individual with investments and assets around the globe, was looking for a suitable EU jurisdiction to consolidate his holdings, relocate his family and become [...]
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So far Markou has created 11 blog entries.
Covid19 - Cyprus Government Response Economic Support Measures to mitigate the effects of COVID19 in the Cyprus economy In the context of the measures taken by the government to support companies / businesses affected by the restrictive measures imposed to limit the spread of COVID19 (Coronavirus), the Government [...]
Disposal of IP Taking advantage of the Cypriot IP Regime The Issue A Cyprus company was the owner of valuable mobile software (IP) used by millions of users in Central Europe. The IP was owned, managed and exploited via a Cyprus company. Once [...]
Franchise expansion to the US Taking advantage of the Cyprus-US double tax treaty The Issue Our client is the owner of a multinational restaurant franchise with licensing arrangements and activities in more than 19 countries. He decided to expand the franchise activities to [...]
Notional Interest Deduction Rates On the table below, you can find the ten-year yield rate of Government bond of each Country, which increased by 3%, represents the “reference rate” for the purpose of granting tax allowance on new capital, as per article 9B of the Income Tax Law L.118(I)/2002. [...]
Cyprus Notional Interest Deduction (NID) Introduction Generally, companies can be financed via debt, equity or a mixture of both. On the one hand, debt generates interest expense, which is usually a tax-deductible expense for the borrower. Equity on the other hand is associated with dividends, which are not deductible for [...]
Cyprus Tax Resident Certificate for individuals Introduction We set out below the main requirements and conditions that must be met for an individual to obtain a tax residency certificate from the Cypriot Tax Department. A tax resident certificate is usually requested by foreign tax authorities in order to apply the [...]
Restructuring financing vehicle Unwinding back to back loans The Issue We were approached by a foreign advisor in relation to a Cypriot financing structure created a number of years ago. The structure included a BVI entity, Cypriot holding and financing companies and underlying [...]
Cyprus - Kazakhstan Double Tax Treaty enters into force On 30 December 2019, the President of Kazakhstan signed into Law the Cyprus - Kazakhstan Double Tax Treaty following its ratification by the Kazakh Parliament. The Treaty was previously ratified by Cyprus on 24 May 2019. On 17 January 2020 Cyprus and [...]
Ratification of Protocol to the Cyprus - Ukraine Double Tax Treaty On 30 October 2019, the Ukrainian parliament enacted and ratified the protocol signed on 11 December 2015 to the Cyprus - Ukraine Double Tax Treaty. As the protocol was previously ratified by Cyprus, the amending protocol is now in force and [...]