The need to enhance substance becomes increasingly important. Our firm can help you to analyse substance requirements and implement tailor-made solutions.

The international tax landscape is changing worldwide. It is becoming increasingly clear that it is not a matter of moving from one jurisdiction to another: the initiatives undertaken by the G20 and the OECD are global in their reach and wide in their scope.

It is important to remain ahead of the developments and be well prepared for the challenges that lie ahead.

Substance in Cyprus is vital in order to:

  • support Cyprus tax residency status;
  • avoid creating a taxable presence in another jurisdiction;
  • support transfer pricing challenges;
  • defend beneficial ownership challenges;
  • address increased anti-avoidance and anti-abuse provisions;
  • exchange information transparently and confidently.

Our firm can assist you with the following services:

  • Diagnostics of the tax risks arising in the existing structure;
  • Recommendations on the actions required to deal with these risks including aligning the following:
    – Split of functions and risks between foreign jurisdiction and Cyprus
    – Supporting of the desired functions and risks in the foreign jurisdiction and Cyprus with the corresponding substance in terms of decision-makers/employees’ location and documentation structure
  • Assistance in the implementation of substance recommendations following the diagnostic review;
  • Assistance in preparing a comprehensive corporate governance framework;
  • Setting-up an office and hiring employees in Cyprus (including assistance in drafting employment contracts, obtaining work permits and optimization of taxation and social security liabilities with respect to the employees);
  • Organization of decision-making process in relation to operational and strategic matters;
  • Providing support in relation to administrative issues (assistance in accounting functions, tax compliance, audit) of the Cypriot companies
Enhancing substance in Cyprus 08/06/2016