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 [...]
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 [...]
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 [...]
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 [...]
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