Intra – group financing transactions. Circular issued from Cyprus Tax authorities On 30 June 2017 the Cyprus Tax Authorities issued a circular providing guidance regarding the tax treatment of the intra – group financing transactions following the abolishment of the minimum margin scheme from 01/07/2017. The circular applies for existing and future financing transactions, therefore existing arrangements need to be revised in terms to comply […]
The Cyprus Tax Authorities issued an announcement where they give guidance regarding the implementation of the scheme. Important aspects of the law/scheme: 1. Type of taxes covered under the scheme a. Income Tax b. Special Defence Contribution c. Capital Gains Tax d. Inheritance Tax e. Immovable property tax f. Special Contribution g. Stamp Duty h. VAT 2. Periods covered a. All taxes due for the […]
On February 2017, the Cyprus tax department (CTD) has send a letter to the Institute of Chartered Accountants (ICPAC) relating to the minimum margins on back to back loans transactions that CTD used to accept. As per the letter, the existing regime (with the minimum margin requirements) will be abolished from 01/07/2017 onwards. This decision was taken due to the international tax developments (OECD/G20 initiative […]
Postponement of application of Article 13 “Capital Gains” of the double tax treaty between Cyprus and Russia. The related article relates to taxes on gains on sale of shares of companies that derive more than 50% of their value from investment property. As per the double tax treaty from 01.01.2017 each contracting state could impose tax on such profits. The application of the article has […]
