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Cyprus Substance Diagnostic

 

We assist companies develop value-adding, real solutions using Cyprus as their international business headquarters. Many investors prefer cheap solutions, such as setting up a Cyprus company offering consultancy services, with no economic substance. Under the new international regulatory environment, such entities have a substantial risk of facing challenges by tax authorities.

PKF Cyprus assists you with issues of Cyprus economic substance and beneficial ownership by organising adequate Cyprus substance for your Cyprus business and dealing with matters of beneficial ownership as well as reviewing and assessing you existing structure.

Key areas covered:

1.  Cyprus Substance Diagnostic general

+ Registered Office

+ One permanent director

+ One permanent secretary

+ Telecommunications

+ Management in Cyprus (Board Meetings)

+ Documentation in Cyprus (Minutes, Notes, etc.)

+ Holding company structure

+ Asset and capitalisation structure

+ Income accrual, sources and pay-out

+ Shareholder identity and confidentiality

+ Bank account in CY-registered institution

+ Secondary bank account

+ International transfer documentation compliance

+ Credit transfer barriers

+ Separation of personal and corporate accounts

+ Dividend Income Structure

+ Interest Income Structure

+ Use and Structure of International Collective Investment Schemes (Alternative Investment Funs – AIFs)

+ Use of Cyprus Trust Schemes

+ Review and assessment of existing IPR agreements

+ Development of IPR agreements to comply with new regulations

2.  Cyprus Beneficial Owner Diagnostic

+ Income accrual, sources and pay-out

+ Holding company structure

+ Shareholder identity and confidentiality

3.  Cyprus Banking Security Diagnostic

+ Bank account in CY-registered institution

+ Secondary bank account

+ International transfer documentation compliance

+ Credit transfer barriers

+ Separation of personal and corporate accounts

4.  Cyprus Dividend and Interest Income Diagnostic

+  Dividend Income Structure

+ Interest Income Structure

+  Use and Structure of International Collective Investment Schemes

+ Use of Cyprus Trust Schemes

5.  Management of Intellectual Property Rights (IPR)

+ Review and assessment of existing IPR agreements

+ Development of IPR agreements to comply with new regulations

Each Diagnostic is implemented according to the legal state-of-the-art relating to each component, including:

  1. Applicable Double Taxation Treaties
  2. OECD BEPS Guidelines
  3. European Commission Parent-Subsidiary Directive
  4. Cyprus Law

All Diagnostic results are implemented by PKF Partners in Cyprus, who typically have 15-20 years experience in senior accounting and audit positions, gained through multi-sectoral engagements. Additional support is provided by in-house and external lawyers where needed. Additional support from PKF’s office of 200 international tax offices is also available.

All Diagnostic results are presented to clients in a face-to-face presentation, accompanied by a specific, detailed assessment and recommendations on how to improve their performance.

Contact us

Please contact us to discuss your requirements for a confidential business Diagnostic at:

Email: [email protected]

 

The authors expressly disclaim all and any liability and responsibility to any person, entity or corporation who acts or fails to act as a consequence of any reliance upon the whole or any part of the contents of this publication.

Accordingly no person, entity or corporation should act or rely upon any matter or information as contained or implied within this publication without first obtaining advice from an appropriately qualified professional person or firm of advisors, and ensuring that such advice specifically relates to their particular circumstances.

PKF Cyprus firms are member firms of the PKF International Limited network of legally independent firms and do not accept any responsibility or liability for the actions or inactions on the part of any other individual member firm or firms.

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