Taxation of P2P Interest Income Recently we assisted a European private investor relocating to Cyprus. As part of our pre-arrival planning, we reviewed his worldwide incomes to determine his tax position in Cyprus and his global effective tax rate. Upon review, we determined that the majority of his incomes emanated [...]
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 tax [...]
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 the [...]
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 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 foreign [...]
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