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The general business environment and supporting facilities,
combined with the island's privileged position, the generous
tax incentives, the low operating costs and concessions available
to international business entities as well as the high standard
of professional services and telecommunications, contributed
to the development of the island as one of the world's primary
business and financial offshore centres. An international
business in Cyprus is essentially a legal entity registered
in Cyprus, whose business activities lie outside the Republic
and whose ownership belongs, directly or indirectly exclusively
to aliens. The main benefits to the international investor
for forming an international business company are low taxation,
shareholder anonymity and freedom of exchange controls. A
synopsis of the more significant of the advantages offered
by Cyprus that would be of particular interest to offshore
entities and their foreign employees are the following:
Tax incentives:
- Cyprus has concluded an impressive and increasing number
of double tax treaties (see separate section below entitled
"Double Tax Treaties").
International business companies are taxed at the reduced
rate of 4,25%.
- International business branches managed and controlled
in Cyprus are taxed at the reduced rate of 4,25%.
- International business partnerships are completely tax
exempt.
- International business branches managed and controlled
abroad are completely tax exempt.
- No withholding tax is payable on dividends, interest and
royalty payments.
- Annual capital allowances and all expenses incurred for
the earning of income are allowed as deductions for tax
purposes.
- Foreign employees of international business entities employed
in Cyprus are liable to Cyprus income tax at reduced rates
that can vary from 0% to a maximum of 20% which are equal
to one half of the normal tax rates.
- The salaries of foreign employees of international business
entities employed outside Cyprus are tax exempt if remitted
through Cyprus.
- The salaries of foreign employees of international business
entities who are employed outside Cyprus and are not paid
through Cyprus are liable to income tax at reduced rates
varying from 0% to 4% which are equal to one tenth of the
normal tax rates.
- Shares in international business companies inherited in
Cyprus are exempt from estate duty.
- Full tax exemption of income derived by way of interest
on foreign capital imported into Cyprus and deposited with
banks operating in Cyprus.
- International business entities are exempt from stamp
duty on any instrument relating to their normal trading
activities.
- International business entities are exempt from special
defence contribution.
- Full capital gains tax exemption is given on capital gains,
except on sale of immovable estate situated in Cyprus.
- International business entities are fully exempt from
local social insurance schemes in respect of their foreign
employees.
- International business entities are outside the scope
of the VAT system.
- No VAT is imposed on the telecommunication services provided
to international business companies with offices in Cyprus
(zero rated for VAT purposes).
Other advantages
- There are no exchange control restrictions on international
business entities and their expatriate employees can maintain
bank accounts in any currency anywhere in the world.
- Cyprus is strategically situated at the cross-roads of
Africa, Asia and Europe and offers excellent climatic and
living conditions.
- It is internationally accessible by sea and air via frequent
daily connections.
- It has a well developed infrastructure with excellent
telecommunication and banking facilities.
- The Cyprus legal system is non-discriminating and is based
on its English counterpart.
- Cyprus has a free enterprise economy, democratic political
system and pluralistic social structure.
- The professional and management services offered in Cyprus
are of a very high standard.
- Housing and office accommodation is easily available at
reasonable prices.
- Cars, office and household equipment (except furniture
and air conditioning equipment) are exempt from import duty
if acquired for the use by an international business entity
and its foreign employees.
- Foreign employees of international business entities and
their family members can secure work and residence permits
very easily.
- Details of beneficial owners are confidentially disclosed
to the Central Bank only and anonymity is therefore assured.
- International business companies and their expatriate
employees are allowed to purchase immovable property in
Cyprus for their own use office premises or their residence
(subject to obtaining the relevant Council of Ministers'
approval).
- The Authorities of Cyprus have repeatedly declared that
they are ready to interpret existing legislation as liberally
as possible and even to introduce new legislation where
necessary, in order to improve the already favourable environment
for both international business entities and those seeking
an operational base in a low-cost, low-tax area.
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| Double Tax Treaties
Cyprus has concluded an impressive number of treaties for
the avoidance of double taxation. There are currently 26 in
force. The existence of these treaties, combined with the
low tax paid by offshore enterprises, and the nil witholding
tax rate on dividends, interest and royalties, offer significant
possibilities for international tax planning through the island.
For example, in the case of a group of companies operating
worldwide, the countries where the group has high tax liabilities
are identified and, in arms length manner, the Cyprus company
through charges, reinvoicing, royalties, interest e.t.c. lowers
profits in the high tax country and declares them for taxation
in Cyprus at a much lower rate.
Conclusion
Summing up we must stress that Cyprus is not a "tax
heaven" with "zero tax" regime, but a reputable
"tax incentive" country with low tax coupled with
an impressive network of double tax treaties, offering tremendous
possibilities for international tax planning.
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