Category: Cyprus

Cyprus: The True Impact Of BEPS On International Business Structures

In the last decade, OECD officials have recommended measures to combat tax avoidance, culminating first in the BEPS (Base Erosion and Profit Shifting) initiative in 2015 and then the MLI (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS) effective from July 2018 – yet have all their… – Continue reading

Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies

On 24 May 2019, Cyprus ratified the first-time double tax treaty it had signed with Kazakhstan on 15 May 2019 (the DTT). Certain legal procedures now need to take place in both states following which the DTT will ‘enter into force’. The DTT will be ‘in effect’ as from the… – Continue reading

Cyprus to adopt new Transfer Pricing regime

After consulting with professionals in the Mediterranean island’s service sector the Finance Ministry is drafting a bill on Transfer Pricing guidelines. The Transfer Pricing regime concerns tax treatment of intra-group financing transactions. The draft bill aims to put an end to the over-pricing of intra-group invoices so that any low… – Continue reading

Cyprus and Kazakhstan sign Double Taxation Convention

The Republic of Cyprus and Kazakhstan signed on Wednesday a Convention for the Avoidance of Double Taxation and for the combating of Tax Evasion with respect to taxes on income. According to a press release issued by the Public Information Office, the Convention was signed in Nursultan, Kazakhstan, by the… – Continue reading

Cyprus: The Cyprus ‘Non-Dom’ Rules

Introduction In July 2015, a number of bills relating to the Cyprus taxation system were approved by the Council of Ministers and subsequently enacted into legislation by the Parliament1. The key highlight of these new bills is the introduction for the very first time of the “non-dom” status for Cyprus… – Continue reading

Cyprus: Entry Into Force Of The Protocol Amending The Convention On The Avoidance Of Double Taxation Between Cyprus And Mauritius

The Cyprus Tax Department has announced that the procedures for ratification of the protocol dated 23 October 2017 amending the Convention on the Avoidance of Double Taxation between Cyprus and Mauritius have been completed, and the protocol entered into force on 2 May 2018. The protocol replaces text of article… – Continue reading

Cyprus: Approach Of Greek Authorities In Determining A Valid Foreign Proof Of Tax Residence

In Greece, an individual who has moved abroad must file an application to the local authorities in order to demonstrate a new address should they wish to change their status from resident to non-tax resident. Such an application is typically filed by March 10th of the year following the year… – Continue reading

UK court refuses to extradite former Trust Bank owner to Russia

Magistrates’ Court ruled that Ilya Yurov persecution was politically motivated because of his connections with Khodorkovsky. Westminster Magistrates’ Court refused to extradite Ilya Yurov, the former part owner of Trust Bank, who is on the international wanted list, RBC reported. The court believes that the extradition would violate human rights…. – Continue reading

Crypto Islands as Double Offshore

There is a small island in the Caribbean … You immediately imagine relaxation, a beach, palm trees. However today in these small areas a really big crypto history is being created. The crypto business is increasingly mastering the jurisdiction of “dwarf” states, such as Cyprus, Malta, Gibraltar, The Republic of… – Continue reading

Europe wages war on Russian oligarchs as London and Cyprus tighten regulations for banking operations

London and Cyprus have tightened the regulations for banking operations, and the accounts belonging to Russians face blocking. Last weekend, Britain said it could block the bank accounts of about 100 foreigners. The assets will be frozen unless their owners provide information on the source of the money. At the… – Continue reading

Cyprus and UK sign updated Convention on the Elimination of Double Taxation

The Republic of Cyprus and the Government of the United Kingdom of Great Britain and Northern Ireland, signed on March 22, in Nicosia, an updated Convention on the Elimination of Double Taxation with respect to Taxes on Income and on Capital Earnings and the Prevention of Tax Evasion of tax… – Continue reading

Cyprus, UK sign updated double taxation treaty

Cyprus and the UK on Thursday signed an updated agreement on double taxation avoidance on income and capital, which will contribute to further develop commercial and financial relations between the two countries. The agreement, signed in Nicosia by Finance Minister Harris Georgiades and British High Commissioner Matthew Kidd, is based… – Continue reading

Cyprus Extends Deadline For CbC Reporting Entity Notification

The Cypriot tax authority has extended until January 15, 2018, the deadline for multinational corporations to submit their notifications concerning country-by-country reporting for 2017. The deadline had been December 31. In December 2016, Cyprus issued a decree introducing CbC reporting obligations for multinational enterprises with consolidated group revenue of EUR750m… – Continue reading

Revised tax treaty to boost bilateral investment: Cyprus envoy

Kolkata, Nov 25 (PTI) The revised tax treaty between Indian and Cyprus will promote bilateral investments, a diplomat said here today. The two countries signed the revised India-Cyprus Double Taxation Avoidance Agreement in November, 2016. “I believe with new taxation agreement, investment from both sides will increase,” High Commissioner of… – Continue reading

Danish bank accused of Russia money laundering

Denmark’s top lender, Danske Bank, played an “organised” role in a Russian money-laundering scam, French prosecutors have said. The Tribunal de Grande Instance de Paris said the bank’s branch in Estonia helped to move €15 million of “money from organised fraud and tax evasion” in Russia into France and other… – Continue reading

Russian Tax Service approves British Virgin Islands’ removal from offshore list

The Federal Tax Service (FTS) removes the British Virgin Islands (BVI) from the black list of ‘tax havens’. This change will affect the interests of Russian owners of the local companies. Leaving BVI for another offshore may help them keep their secrets, but not forever. Removal of the BVI from… – Continue reading

EU Countries Seek Legislative End-Around on Digital Tech Tax

EU nations led by France and Italy reinforced the need for an “equalization tax” or turnover tax on large internet companies such as Facebook Inc. and Amazon.com Inc., and suggested they would use special legislative procedures to impose one in the event all 28 EU-member countries don’t back the levy…. – Continue reading

Donohoe says Ireland opposes ‘equalisation tax’ at EU meeting

The proposals plan to tax giant digital companies on turnover rather than profits EU finance ministers have agreed to step up technical work on harmonising the taxation of the giant digital companies with a view to debating “possible solutions” at their December meeting. The ministerial consensus was a significant setback… – Continue reading

Panama probe: First prosecutions are taken to court for off-shore tax evasion

While at the beginning of the year (The Indian Express, March 16, 2017) the number of requests sent by India stood at 283 cases, it has now crossed 300. And while the number of replies received from among these 13 jurisdictions stood at 165, that figure has now crossed 240…. – Continue reading

EU Takes Legal Action Against Portugal, Two Others on Tax Deals

The European Commission launched legal proceedings against Portugal, Bulgaria, and Cyprus for not adopting, in their national laws, European Union legislation requiring all EU countries to exchange tax rulings granted to multilateral companies. The legislation was adopted in the wake of the 2014 LuxLeaks scandal that revealed more than 100… – Continue reading

European Commission warns Bulgaria to get into line on tax rulings, anti-trust damages actions rules

Bulgaria is among European Union countries that the European Commission has sent a reasoned opinion because of its failure to communicate the transposition of new measures on the automatic exchange of tax rulings between EU tax authorities. The step was announced by the European Commission on July 13, among its… – Continue reading

Cyprus releases long-awaited Transfer Pricing guidelines on intra-group financing

As of 1st July 2017, the tax treatment of intra-group financing arrangements has been amended in Cyprus. Intra-group financing transactions refers to finance activities between related parties (as defined in Section 33 of the Income Tax Law), including permanent establishments in Cyprus. Based on the Interpretative Circular issued by the… – Continue reading

Cyprus: Saying Goodbye To Back To Back Loans And Welcoming Transfer Pricing Regulations

A. Introduction In February 2017 Cyprus Tax Department has announced that the current practice regarding profit margins between related Company loans will be abolished by the 30th June 2017. The announcement indicates that the minimum acceptable margins will apply up to 30th June 2017, and as from 1st July 2017… – Continue reading

Cyprus: Tax Evasion Or Tax Avoidance: A Predicate Offence Under Cyprus Anti-Money Laundering Laws?

Money laundering offences usually consist of conduct which seeks to conceal the criminal origin of wealth. When it was first introduced into the legal order in the 1980s, the principal objective of anti-money laundering legislation was to combat the introduction of the proceeds of drug dealing into the legitimate economy… – Continue reading

Cyprus and Luxembourg object to a proposed EU common corporate tax base directive

Cyprus and Luxembourg, two of the EU`s financial centres, on Monday cautioned against the implementation of the proposed Common Consolidated Corporate Tax Base (CCTB) in the European Union. “Cyprus believes that we should be very cautious and very careful when it comes to corporate taxation,” Cypriot Finance Minister Harris Georgiades… – Continue reading

Cyprus: Abolition Of Profit Margins On Intra Group Loans – Upcoming Transfer Pricing Legislation – Transfer Pricing Studies Requirement

As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length… – Continue reading

Russian Federation: Confirmation Of Direct Investment In Capital To Apply A Reduced Tax Rate On Payment Of Dividends

On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading

Multilateral Instrument: The new dilemma of foreign investors

MUMBAI: The Multilateral Instrument (MLI), a new global tax avoidance agreement, that is in the process of being signed by 100 countries, is now causing a lot of anxiety among foreign portfolio investors (FPIs). MLI is an agreement put out by OECD, the intergovernmental economic organisation, to stop Base Erosion… – Continue reading

International tax-avoidance rules may override GAAR, other tax treaties

There is a possibility that the General Anti-Avoidance Rules (GAAR, on taxes) and the tax treaties signed by the government with those of Mauritius, Singapore and Cyprus, and even other nations such as Netherlands, could be overtaken by another event. These could, say experts, be partially or fully overridden by… – Continue reading

New tax regime for Ukrainian loan participation notes issued on international capital markets

January 2017 – On 21 December 2016, Ukraine’s parliament adopted the Law “On Amendments to the Tax Code of Ukraine Concerning Improvement of the Investment Climate in Ukraine” No. 1797-19. With effect from 1 January 2017, the legislation introduces new rules for the taxation of interest payable by Ukrainian economic… – Continue reading

Budget 2017: Tax Reform For Financial Services

Given the recent developments in the Indian economy, the upcoming Union Budget will certainly be critical and important in determining the future outlook of the economy. The financial services industry has been one of the key drivers of growth due to its strong cause and effect relationship with the economy…. – Continue reading

Moving towards a simplified tax regime

As per the Economic Survey 2016, the ratio of Indian taxpayers to voters is 4%; ideally it should be roughly 23% at existing levels of economic and political development. The tax to GDP ratio at 16.6% is well below the emerging market economy norm of 21% and OECD average of 34%…. – Continue reading

India may leave tax treaty with Netherlands unchanged

India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend… – Continue reading

Cyprus: Country-By-Country Reporting Under Base Erosion And Profit Shifting Action 13

Cyprus signed the Organisation for Economic Co-operation and Development’s Multilateral Competent Authority Agreement for the Automatic Exchange of Country-by Country Reports between its member states on 1 November 2016 after approval by the Council of Ministers at its meeting held on 28 September 2016. Following publication in the government gazette… – Continue reading

Singapore Goes The Mauritius Route, Loses Right To Tax Equity Capital Gains Arising In India

Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a… – Continue reading

India removes Cyprus from tax blacklist

Cyprus has been formally removed from India’s tax blacklist and will now not be considered as ‘non-cooperative’ jurisdiction for income tax purposes. The Central Board of Direct Taxes (CBDT) has issued a notification, rescinding it’s executive order blacklisting the island nation from November 1, 2013. Cyprus, a popular tax haven,… – Continue reading

Ireland Rejects Oxfam’s Tax Haven Claims

Ireland’s Ministry of Finance, the EU and several other governments have emphatically rejected claims by Oxfam International that the countries are tax havens, with Ireland insisting its corporate tax laws are “fully compliant” with international best practices when it comes to transparency and information exchange. The Irish government said the… – Continue reading

Oxfam: Luxembourg, Ireland, Netherlands among worst tax havens

The NGO’s report exposes the worst offenders in the ‘race to the bottom on corporate tax.’ Luxembourg, Ireland, Cyprus, and the Netherlands are among the world’s 10 worst tax havens, despite an ongoing EU crackdown on tax avoidance and profit shifting across the bloc. The findings come in a report… – Continue reading

HUNGARY COULD BE A CORPORATE PROFIT TAX HAVEN IN THE EUROPEAN UNION

The new 9 percent flat corporate profit tax – to be introduced 1st of January 2017 – will put Hungary in a very good position in the international race for investments as Hungary will offer even better conditions than Ireland and Cyprus, which are both often regarded as the European… – Continue reading

India, Cyprus ink new Double Tax Avoidance Agreement

New Delhi– India on Friday signed a revised double taxation avoidance agreement (DTAA) with Cyprus, an official statement said here. “A revised agreement between India and Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion (DTAA) with respect to taxes on income, along with its protocol,… – Continue reading

EU agrees screening process for tax havens, critics cry foul

European Union finance ministers agreed on Tuesday how to screen countries for a blacklist of tax havens across the world, officials said, and said applying zero-rate taxes was not necessarily a factor, prompting an outcry. The bloc committed in May to agree on a common list of tax offenders by… – Continue reading