EFFICIENT TAX STRUCTURES FOR INTERNATIONAL INVESTMENTS THROUGH CYPRUS COMPANIES

CYPRUS COMPANIES ARE THE MOST EFFECTIVE VEHICLES FOR INTERNATIONAL INVESTMENTS AND TAX PLANNING CYPRUS IS NOT AN OFFSHORE JURISDICTION BUT A RESPECTABLE TAX REGIME ACCEPTABLE BY EU AND OECD WITH THE LOWEST TAX RATE IN EU @10% WITH LONG AND STABLE FISCAL HISTORY & STRONG ECONOMY THAT ENABLES IT TO MAINTAIN IT MEMBER OF EU CAN BENEFIT OF EU DIRECTIVES WITH AN EXTENSIVE DOUBLE TAX TREATY NETWORK WITH ALMOST 50 COUNTRIES OFFERING MANY OPPORTUNITIES FOR EFFECTIVE TAX PLANNING WITH THE BEST DOUBLE TAX TREATY EVER CONCLUDED WITH RUSSIA &UKRAINE &OTHER CIS COUNTRIES WITH VERY GOOD DOUBLE TAX TREATIES WITH OTHER EMERGING MARKETS WHICH ATTRACT THE INTEREST OF THE INTERNATIONAL INVESTOR LIKE CHINA AND INDIA WITH PARTICIPATION EXEMPTION ON DIVIDENDS –subject to minimal conditions & FULL PARTICIPATION EXEMPTION ON DISPOSAL OF SHARES without minimum holding period or shareholding unlike other international business companies like UK or Dutch UNILATERAL CREDIT RELIEF FOR FOREIGN TAXES, NO CFC LEGISLATION, NO THIN CAPITALISATION RULES OR TRANSFER PRICING RULES NO WHT ON DIVIDENDS PAID EVEN IF THEY ARE PAID TO OFFHSORE C OMPANIES

CYPRUS TRADING COMPANY AS A TRADING COMPANY EXPORT ISRAELI CO IMPORT COMPANY NET PROFIT IS TAXED IN CYPRUS AT 10% SUBSTANCE OF THE CYPRUS COMPANY IS IMPORTANT MANY IMPORTANT ISRAELI COS HAVE THEIR BASE IN CYPRUS DUE TO THE COST EFFICIENT AND DEVELOPED BUSINESS ENVIRONMENT CYPRUS CAN GIVE ACCESS TO NEW EXPORT MARKETS TO ISRAELI COs CYPRUS TRADING COMPANY

AS INVESTOR IN ESTATE CO PROPERTY OWNED BY ESTATE CO ABROAD IS SOLD BY DISPOSING THE SHARES OF THE CYPRUS CO BEING THE SOLE SHAREHOLDER OF THE ESTATE CO 0% TAX ON PROFIT FROM DISPOSAL OF SHARES HOLDING CYPRUS CO ESTATE CO ABROAD PROPERTY ABROAD PROPERTY ABROAD

AS AN INVESTMENT COMPANY TRADING IN SECURITIES INVESTOR PROFIT IS TAX EXEMPT USE OF DOUBLE TAX TREATIES NO WITHHOLDING TAX ON DIVIDENDS OUT OF CYPRUS CYPRUS CO TRADING IN SECURITIES BUY SECURITIES SELL SECURITIES

AS A HOLDING COMPANY NO WITHHOLDING TAX ON DIVIDEND PAID FROM EU SUBSIDIARIES LOWERS WITHHOLDING TAX FROM TREATY SUBSIDIARY 0% TAX IN CYPRUS ON DIVIDEND ;DIVIDEND PARTICIPATION EXEMPTION NO WITHHOLDING TAX ON DIVIDEND PAID TO NON RESIDENT BY CYPRUS CO ULTIMATE HOLDING CO CYPRUS HOLDING CO TREATY SUBSIDIARY EU SUBSIDIARY

AS A FINANCE COMPANY CYPRUS CO. IS USED TO FINANCE A TRADING CO. IN ANOTHER COUNTRY SMALL MARGIN TAXABLE AT 10% IN CYPRUS NO WITHHOLDING TAX HEAVEN COMPANY CYPRUS FINANCING CO OPERATING CO

CYPRUS CO AS A ROYALTY COMPANY PLAN: PARENT Co. ESTABLISHES CYPRUS ROYALTY Co. TO COLLECT ROYALTIES FROM Co. IN EU COUNTRY OR TREATY COUNTRY BENEFITS: 10% TAX ON PROFIT IN CYPRUS ON THE NET AMOUNT OF THE ROYALTY INCOME ROYALTY IS DEDUCTED FROM TAXABLE PROFIT IN PAYING COMPANY NO WHT ON ROYALTY FROM CYPRUS TO THE PARENT Co. OR ANOTHER FRANCHISOR NO WHT IF ROYALTY IS PAID BY EU Co. OR LOWER OR EVEN ZERO IF PAID FROM TREATY COUNTRY DEPENDING ON THE DTT PARENT Co. OR FRANCHISOR 0 WHT CYPRUS ROYALTY Co. 10% 0 WHT OR LOWER WHT FOR SOME TREATY COUNTRIES EU/TREATY OPERATING Co.

CYPRUS HOLDING COMPANY FOR INVESTMENTS TO RUSSIA, UKRAINE &OTHER CIS COUNTRIES CYPRUS HAS THE BEST DTT WITH RUSSIA, UKRAINE &OTHER CIS COUNTRIES DIVIDEND WHT UKRAINE 0% RUSSIA 5% ( OR 10% FOR INVESTMENTS BELOW € 100.000) WHT ON INTEREST FOR BOTH COUNTRIES 0% WHT ON ROYALTIES FOR BOTH COUNTRIES 0%

CYPRUS HOLDING COMPANY FOR RUSSIA & UKRAINE PARENT TAX EFFICIENT HOLDING STRUCTURE DUE TO FAVOURABLE DOUBLE TAX TREATY PERMITS THE FLOW OF PROFITS (VIA DIVIDENDS) FROM RUSSIA/UKRAINE TO A FOREIGN PARENT CO WITH MINIMAL TAX BURDEN DIVIDEND WHT RUSSIA 5% UKRAINE 0% NO TAX IN CYPRUS ON DIVIDEND FLOWS NO WHT ON DIVIDEND FROM CY Co. 0% Dividend CYPRUS COMPANY 0% Dividend 5% Russia 0% Ukraine RUSSIAN Co. OR UKRAINE Co.

CYPRUS HOLDING COMPANY FOR INVESTMENTS TO CHINA 15/04/2017 CYPRUS HOLDING COMPANY FOR INVESTMENTS TO CHINA CHINA IS THE FASTEST GROWING ECONOMY IN THE WORLD ATTRACTING HIGH INBOUND INVESTMENTS CHINA ISSUED NEW TAX RULES 1 JANUARY 2008 RELEVANT TO INBOUND INVESTORS WITHHOLDING TAX OF 10% INSTEAD OF NIL ON DIVIDENDS FROM FOREIGN INVESTMENT ENTERPRISES WITHHOLDING TAX FROM 10% ON CHINA-SOURCED PASSIVE INCOME (E.G. DIVIDENDS, INTEREST, RENTS, CAPITAL GAINS, etc) TAX PLANNING OF INBOUND INVESTMENTS IS NOW EVEN MORE ESSENTIAL CYPRUS CHINA DTT: 10% WHT ON DIVIDEND, INTEREST & ROYALTY; NO CGT ON PROFIT FROM SALE OF SHARES OF CY CO IF IT HOLDS LESS THAN 25% IN CHINESE CO 11 11

CYPRUS HOLDING COMPANY-CHINESE INBOUND INVESTMENT PLAN ESTABLISH CYPRUS COMPANY TO HOLD OPERATING SUBSIDIARY IN CHINA FOR DIVIDEND STREAM INCOME THROUGH WHICH CAPITAL WILL FLOW INTO CHINA BENEFITS WITHHOLDING TAX IN CHINA ON DIVIDEND PAYMENT TO CYPRUS AT 10% DIVIDEND RECEIVED IN CYPRUS IS TAX EXEMPT NO WITHHOLDING TAX ON DIVIDENDS TO PARENT WHETHER EU OR NON-EU EU PARENT NON-EU PARENT WHT ON DIVIDEND PAID 0% CYPRUS HOLDING COMPANY TAX ON DIVIDEND RECEIVED 0% CHINESE OPERATING COMPANY WHT ON DIVIDEND PAID 10%

CHINESE INBOUND INVESTMENT THROUGH CYPRUS AND HONG KONG CO PLAN ESTABLISH CYPRUS COMPANY TO HOLD OPERATING SUBSIDIARY IN CHINA THROUGH HONG KONG CO FOR DIVIDEND STREAM INCOME THROUGH WHICH CAPITAL WILL FLOW INTO CHINA BENEFITS WITHHOLDING TAX ON DIVIDEND FROM CHINA TO HONG KONG IS FURTHER REDUCED TO 5%DUE TO THE DTT BETWEEN CHINA HK DIVIDEND RECEIVED IN CYPRUS IS TAX EXEMPT NO WITHHOLDING TAX ON DIVIDENDS TO PARENT WHETHER EU OR NON-EU IN CASE OF DISPOSAL OF THE INVESTMENT THE SHARES OF THE CYPRUS HOLDING CO ARE SOLD AND THE PROFIT IS FULLY TAX EXEMPT EU NON EU WHT ON DIVIDEND PAID 0% CYPRUS HOLDING CO TAX ON DIVIDEND 0% TAX ON DIVIDEND IN HK 0% HONG KONG HOLDING CO WHT ON DIVIDEND PAID 5% CHINESE OPERATING CO

CYPRUS ROYALTY COMPANY-CHINESE INBOUND INVESTMENT NON-EU PARENT EU PARENT Plan Establish Cyprus royalty company to collect royalties from company in China. The Cyprus company is owner of intangible Benefits 10% WHT on royalty in China No additional tax in Cyprus because of treaty tax credit Royalty deductibility in paying company No WHT tax on dividend paid from Cyprus whether to EU or non-EU No WHT on dividend CYPRUS ROYALTY COMPANY No tax on royalty in Cyprus due to tax credit CHINESE OP COMPANY WHT on Royalty 10%

CYPRUS FINANCE COMPANY-CHINESE INBOUND INVESTMENT Plan Establish Cyprus company to be the group finance company of China operations. Capitalisation with equity Benefits No additional tax in Cyprus because of treaty tax credit. Access to the China/Cyprus treaty. Interest deductibility in borrowing company subject to debt-equity ratio No WHT on dividends paid from Cyprus whether to EU or non-EU EU Parent Non EU Parent 0% WHT on Dividend Tax on interest 0% due to tax credit Cyprus Fin Co 10 % WHT on Interest Chinese Op CO

CAPITAL GAINS-CHINESE INBOUND INVESTMENTS When Cyprus company holds less than 25% in Chinese company No tax in China no tax in Cyprus when the shares are sold EU Parent Non EU parent 0 WHT Dividend or Interest 0 WHT Dividend or Interest Cyprus Comp 25% 0 CGT Cy Co5 Cy Co4 Cy Co3 Cy Co2 Cy Co1 Chinese Company When Cyprus company holds more than 25% in Chinese company then the holding can be through a number of Cyprus companies.

CYPRUS HOLDING COMPANY FOR INVESTMENTS TO INDIA BENEFICIAL DOUBLE TAX AGREEMENT WITH INDIA-TAXING RIGHT FOR CHARGEABLE GAINS WITH CYPRUS PARTICIPATION EXEMPTION ON DISPOSAL OF SHARES – FULLY EXEMPT NO WHT ON DIVIDENDS FROM INDIA PARTICIPATION EXEMPTION ON DIVIDENDS-SUBJECT TO MINIMAL CONDITIONS NO CYPRIOT WHT ON DIVIDENDS PAID BY CYPRIOT COMPANIES 17

CYPRUS HOLDING COMPANY FOR INVESTMENTS TO INDIA TAX EFFICIENT HOLDING STRUCTURE NO INDIAN CGT CHARGEABLE CYPRUS DOES NOT TAX DISPOSAL OF SECURITIES NO WHT ON DIVIDENDS FROM INDIA NO TAX IN CYPRUS ON DIVIDEND FLOWS NO WHT ON DIVIDEND FROM CY Co. ParentCo. 0% BVI Dividend 0% CY Co. Dividend 0% India Co. Dividend 0% 0% CGT India Project

LEGAL ASPECTS OF A CYPRUS INTERNATIONAL BUSINESS COMPANY LIMITED COMPANIES PARTNERSHIPS BRANCHES COMPANY INFORMATION FILED AT THE REGISTRAR EASY REGISTRATION PROCEDURE TO SERVE OUR CLIENTS BETTER AND QUICKER WE HAVE READY MADE ‘OFF THE SHELF COMPANIES’

REGISTRATION REQUIREMENTS APPROVAL OF NAME SHARE CAPITAL: MIN € 100 SHAREHOLDER: AT LEAST ONE INDIVIDUAL OR COMPANY-NOMINEE SHAREHOLDER SERVICE DIRECTOR: AT LEAST ONE CYPRIOT OR ALIEN- NOMINEE DIRECTOR SERVICE SECRETARY: INDIVIDUAL OR COMPANY REGISTERED OFFICE IN CYPRUS AUDITED FINANCIAL STATEMENTS

SHAREHOLDING BENEFICIAL SHAREHOLDERS CAN EITHER HAVE THE SHARES REGISTERED IN THEIR NAME AT THE REGISTRAR OF COMPANIES OR CAN USE NOMINEE SERVICES I.E THE SHARES WILL BE HELD BY OUR NOMINEE COMPANIES IN TRUST FOR BENEFICIAL OWNERS TO ENSURE CONFIDENTIALITY

PROTECTION IN CASE OF NOMINEE SHAREHOLDERS REPUTABLE NOMINEES DECLARATION OF TRUST IS ISSUED BY THE NOMINEES SIGNED INSTRUMENT OF SHARE TRANFER IS GIVEN BY THE NOMINEE TO THE BENEFICIAL OWNER CONFIDENTIALITY IS SAFEGUARDED AS : COPY OF THE PASSPORT IS HELD WITH US AND THE BANK ONLY THE BANK DOES NOT DISCLOSE THE INFORMATION UNLESS IN CRIMINAL CASE

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