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Under the current tax legislation, Cyprus has
the lowest tax regime in Europe and its role as an international financial
centre is greatly enhanced. There is no longer a differentiation in the tax
treatment of local companies and International Business Companies as a single
corporation tax rate is applicable for all companies. Cyprus clearly stands as
a prestigious tax - incentive EU country and is be free from suspicions usually
associated with "tax-havens" which have zero tax.
The principal tax and other fiscal incentives
may be outlined as follows (see also Cyprus Tax Reform)
An International Business Company (IBC) will
pay a tax of 10% on its net profits if it is a Cyprus resident. An IBC is resident
if its management and control is in Cyprus. Management and control is usually
determined by the place of residence of the majority of the directors and the
place where board meetings take place. Full advantage of the Cyprus double-tax
treaty network can be obtained by resident IBCs
- An IBC will pay zero tax if it is not
considered to be resident in Cyprus. This will be the case when its management
and control is outside Cyprus.
- A non-resident IBC will not be able to obtain
a Cyprus Tax residence certificate and therefore cannot utilise the double-tax
treaty network.
- There is no withholding tax on payment of
dividends, interest and royalties by an IBC to non-resident individuals or
companies.
- Dividend income received in Cyprus by an IBC
is wholly exempt from tax in Cyprus (under certain conditions).
- Profits earned from a permanent establishment
abroad are fully exempt from corporation tax.
- Profits from the disposal of shares are not
taxable for all Cyprus tax residents.
- 50% of interest received is exempted unless
the interest arises in the ordinary course of business (e.g. interest on
overdue debtor balances).
- There is no restriction in the carry-forward
of tax losses. They can be carried forward indefinitely to be set-off against
future profits.
- Group relief is available whereby losses from
a company can be set off against taxable profits of other companies in the same
group.
- Reorganisations, amalgamations, mergers and
acquisitions of companies can be effected without any tax implications.
- Exemption from capital gains tax (except on
sale of immoveable property situated in Cyprus).
- No exchange control restrictions - an IBC can
open a bank account in any currency in Cyprus and abroad.
- Cyprus has 32 Double Tax Treaty agreements
which apply to 40 countries and which can be exploited to minimise tax.
- Confidentiality and anonymity of beneficial
owners is safeguarded (true identity is only disclosed to local banks, if a
local account is opened and information is not disclosed to any third party or
to other countries, except in the case of properly authorized criminal
investigation (drugs, terrorism, e.t.c.).
Other inherent advantages of Cyprus
Other advantages of more general nature that
Cyprus can offer include:
- Geographical location (at the crossroads of
three continents)
- A stable economy in a western-type democracy
- Legal system based on English Law
- Excellent telecommunications and air
connections
- Excellent banking facilities with worldwide
networks
- High level of professional services
- Readily available and highly trained local
staff
- Relatively low cost of living
- Low crime level
- Excellent schools up to university level
- Excellent climate
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