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 [...]
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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 [...]
Administrative penalties for late filings to the Registrar of Companies New Administrative Fines As from 18 December 2019, the Registrar of Companies will impose administrative fines for late filing of the below notifications to the Registrar of Companies: Late filing of the annual return. The [...]