1. EFFICIENT TAX STRUCTURES FOR INTERNATIONAL INVESTMENTS
THROUGH CYPRUS COMPANIES

2. 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 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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.

9. 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 € )
WHT ON INTEREST FOR BOTH COUNTRIES 0%
WHT ON ROYALTIES FOR BOTH COUNTRIES 0%

10. 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.

11. 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

12. 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%

13. 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

14. 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%

15. 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

16. 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.

17. 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

18. 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

19. 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’

20. 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

21. 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

22. 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

23. THANK YOU GLOBALSERVE CONSULTANTS LTD 9 VASSILI MICHAELIDES
3026, LIMASSOL-CYPRUS
P.O BOX 57048, 3311, LIMASSOL, CYPRUS
TEL ,
FAX
WEB SITE:
CONTACT PERSONS:
DINOS ANTONIOU, C.E.O
PHANI SCHIZA ANTONIOU, MANAGING
DIRECTOR

24. THANK YOU