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UNITED KINGDOM COMPANIES

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					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
       AS A TRADING COMPANY

EXPORT ISRAELI CO            IMPORT COMPANY



                                    NET PROFIT IS TAXED IN
                                    CYPRUS AT 10%
           CYPRUS TRADING COMPANY
                                    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
            AS INVESTOR IN ESTATE CO

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


                                    INVESTOR
 PROFIT IS TAX
EXEMPT

 USE OF DOUBLE
TAX TREATIES                   CYPRUS CO
                          TRADING IN SECURITIES
 NO WITHHOLDING
TAX ON DIVIDENDS
OUT OF CYPRUS


                   BUY SECURITIES          SELL SECURITIES
              AS A HOLDING COMPANY

                                      NO WITHHOLDING TAX
                                     ON DIVIDEND PAID FROM EU
                                     SUBSIDIARIES
        ULTIMATE HOLDING CO
                                      LOWERS WITHHOLDING
                                     TAX FROM TREATY
                                     SUBSIDIARY
         CYPRUS HOLDING CO
                                      0% TAX IN CYPRUS ON
                                     DIVIDEND ;DIVIDEND
                                     PARTICIPATION EXEMPTION

                                      NO WITHHOLDING TAX
                     EU SUBSIDIARY   ON DIVIDEND PAID TO NON
TREATY SUBSIDIARY
                                     RESIDENT BY CYPRUS CO
        AS A FINANCE COMPANY


                                  CYPRUS CO. IS USED
                                 TO FINANCE A TRADING
HEAVEN COMPANY                   CO. IN ANOTHER
                                 COUNTRY

                                  SMALL MARGIN
           CYPRUS FINANCING CO   TAXABLE AT 10% IN
                                 CYPRUS

                                  NO WITHHOLDING
 OPERATING CO                    TAX
  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:
 PARENT Co. OR                 10% TAX ON PROFIT IN CYPRUS ON
  FRANCHISOR                     THE NET AMOUNT OF THE ROYALTY
                 0 WHT           INCOME
                               ROYALTY IS DEDUCTED FROM TAXABLE
                                 PROFIT IN PAYING COMPANY
  CYPRUS          10%          NO WHT ON ROYALTY FROM CYPRUS
 ROYALTY Co.                     TO THE PARENT Co. OR ANOTHER
                                 FRANCHISOR
                  0 WHT OR
                 LOWER WHT     NO WHT IF ROYALTY IS PAID BY EU Co.
                                 OR LOWER OR EVEN ZERO IF PAID
 EU/TREATY        FOR SOME
                                 FROM TREATY COUNTRY DEPENDING
OPERATING Co.       TREATY       ON THE DTT
                  COUNTRIES
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
Dividend                    0%
                                     – PERMITS THE FLOW OF PROFITS (VIA
                                       DIVIDENDS) FROM RUSSIA/UKRAINE
             CYPRUS                    TO A FOREIGN PARENT CO WITH
                            0%
            COMPANY                    MINIMAL TAX BURDEN

Dividend
                        5% Russia    – DIVIDEND WHT
                                         • RUSSIA 5%
                        0% Ukraine       • UKRAINE 0%
           RUSSIAN Co. OR
            UKRAINE Co.              – NO TAX IN CYPRUS ON DIVIDEND
                                       FLOWS

                                     – NO WHT ON DIVIDEND FROM CY Co.
         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
       CYPRUS HOLDING COMPANY-CHINESE
            INBOUND INVESTMENT
                                                      PLAN
             NON-EU PARENT                EU PARENT   • ESTABLISH CYPRUS COMPANY TO
                                                        HOLD OPERATING SUBSIDIARY IN
                                                        CHINA FOR DIVIDEND STREAM
WHT ON DIVIDEND                                         INCOME THROUGH WHICH CAPITAL
PAID 0%                                                 WILL FLOW INTO CHINA

                         CYPRUS HOLDING               BENEFITS
TAX ON DIVIDEND             COMPANY                   • WITHHOLDING TAX IN CHINA ON
RECEIVED 0%                                             DIVIDEND PAYMENT TO CYPRUS AT
                                                        10%
                                                      • DIVIDEND RECEIVED IN CYPRUS IS TAX
                        CHINESE OPERATING               EXEMPT
WHT ON DIVIDEND
                            COMPANY                   • NO WITHHOLDING TAX ON
PAID 10%
                                                        DIVIDENDS TO PARENT WHETHER EU
                                                        OR NON-EU
       CHINESE INBOUND INVESTMENT THROUGH
             CYPRUS AND HONG KONG CO
                                           PLAN
              NON EU                  EU   • ESTABLISH CYPRUS COMPANY TO HOLD
                                             OPERATING SUBSIDIARY IN CHINA THROUGH
                                             HONG KONG CO FOR DIVIDEND STREAM INCOME
WHT ON DIVIDEND                              THROUGH WHICH CAPITAL WILL FLOW INTO
PAID 0%                                      CHINA
TAX ON DIVIDEND 0% CYPRUS                  BENEFITS
                   HOLDING CO
                                           • WITHHOLDING TAX ON DIVIDEND FROM CHINA
TAX ON                                       TO HONG KONG IS FURTHER REDUCED TO 5%DUE
DIVIDEND IN                                  TO THE DTT BETWEEN CHINA HK
HK 0%                  HONG KONG           • DIVIDEND RECEIVED IN CYPRUS IS TAX EXEMPT
                       HOLDING CO
                                           • NO WITHHOLDING TAX ON DIVIDENDS TO
                                             PARENT WHETHER EU OR NON-EU
                                           • IN CASE OF DISPOSAL OF THE INVESTMENT THE
WHT ON                 CHINESE               SHARES OF THE CYPRUS HOLDING CO ARE SOLD
DIVIDEND               OPERATING CO
                                             AND THE PROFIT IS FULLY TAX EXEMPT
PAID 5%
              CYPRUS ROYALTY COMPANY-CHINESE
                   INBOUND INVESTMENT

     NON-EU PARENT             EU PARENT   Plan
                                           Establish Cyprus royalty company
                                           to collect royalties from company
 No WHT on                                 in China. The Cyprus company is
 dividend
                                           owner of intangible
                     CYPRUS ROYALTY        Benefits
No tax on               COMPANY
royalty in                                 •10% WHT on royalty in China
Cyprus
                                           •No additional tax in Cyprus
due to tax
credit                                     because of treaty tax credit
                                           •Royalty deductibility in paying
WHT on                 CHINESE OP
                        COMPANY            company
Royalty 10%
                                           •No WHT tax on dividend paid
                                           from Cyprus whether to EU or
                                           non-EU
CYPRUS FINANCE COMPANY-CHINESE
     INBOUND INVESTMENT
                                              Plan
                                              •Establish Cyprus company to
                                              be the group finance company
EU Parent              Non EU Parent
                                              of China operations.
                                              Capitalisation with equity
                         0% WHT on Dividend   •Benefits
                                              •No additional tax in Cyprus
                             Tax on
                             interest         because of treaty tax credit.
       Cyprus Fin Co
                             0% due to        •Access to the China/Cyprus
                             tax credit       treaty.
                            10 % WHT on
                                              •Interest deductibility in
                            Interest          borrowing company subject to
      Chinese Op CO
                                              debt-equity ratio
                                              •No WHT on dividends paid
                                              from Cyprus whether to EU or
                                              non-EU
              CAPITAL GAINS-CHINESE INBOUND
                       INVESTMENTS
                                                                  •When Cyprus company
                EU                Non EU                          holds less
0 WHT         Parent              parent         0 WHT            than 25% in Chinese company
Dividend or                                      Dividend or
Interest                                         Interest         • No tax in China no tax in
                                                                  Cyprus
                   Cyprus
                                                                    when the shares are sold
                   Comp                    25%
  0 CGT




        Cy Co1          Cy Co2        Cy Co3             Cy Co4    Cy Co5

                                                                  When Cyprus company holds
                                                                  more than 25% in Chinese
                        Chinese                                   company then the holding can
                       Company                                    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
CYPRUS HOLDING COMPANY FOR INVESTMENTS TO INDIA

                                 • TAX EFFICIENT HOLDING
   ParentCo.        0%           STRUCTURE

                                 • NO INDIAN CGT
                   Dividend 0%   CHARGEABLE
      BVI
                                 • CYPRUS DOES NOT TAX
                                 DISPOSAL OF SECURITIES
                   Dividend 0%
    CY Co.                       • NO WHT ON DIVIDENDS
                                 FROM INDIA

   India Co.       Dividend 0%   • NO TAX IN CYPRUS ON
                                 DIVIDEND FLOWS
                   0% CGT
                                 • NO WHT ON DIVIDEND
   India Project                 FROM CY Co.
    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
THANK YOU
 GLOBALSERVE CONSULTANTS LTD
 9 VASSILI MICHAELIDES
 3026, LIMASSOL-CYPRUS
 P.O BOX 57048, 3311, LIMASSOL, CYPRUS

 TEL. 00357 25 817181, 00357 25 824545
 FAX. 00357 25 824055

 WEB SITE: www.globalserve.com.cy
 EMAIL: info@globalserve.com.cy

 CONTACT PERSONS:
 DINOS ANTONIOU, C.E.O
 PHANI SCHIZA ANTONIOU, MANAGING
 DIRECTOR
THANK YOU

				
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posted:10/15/2011
language:English
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