Scenario: A Cyprus resident trading/financing Company issues new capital comprising of 1000 shares, with a nominal value of €1 each at a premium of €999 per share (total new equity €1.000.000). The funds are utilized in the business and generate income of i.e. €200.000. Reference Rate for year 2016 as published by the Cyprus Tax Department for funds employed in i.e. Ukraine at 9.622% (NID rate).
back-to-back loan arrangement
For example, instead of engaging the Cyprus Company through back-to-back loan arrangement, one can take advantage of the NID provisions and grant out a loan through own funds that were introduced in the share capital of the Cyprus Company.
Cyprus resident Companies
Cyprus resident Companies are entitled to a Notional Interest Deduction (NID) of up to 80% of their taxable income on qualifying new equity. Qualifying new equity includes share capital of any class and share premium issued and settled after 1 January 2015 paid either in cash or in kind.
The above provision, apart from reducing the effective tax of the Cyprus Company by up to 80% thereby decreasing the effective tax rate to as low as 2.5% can also allow for the Cyprus Company to be the beneficial owner of income. Especially in the cases where loans are granted by the Cyprus Company the resulting tax charge can be as low or even lower than in the case of using thin spreads (back-to-back arrangement).
Cyprus Cooperate Services Simplified
At MariCorp we target to simplify Corporate Services as a whole and offer our clients a straightforward and simple solution.
Effective Tax = 2.5% (€1.750/€70.000)
Graduated from Liverpool John Moores University in 2011. Became a member of the Institute of Chartered Accountants of England and Wales (ICAEW) in 2015. Currently undergoing Certified Fraud Examiner (CFE) Level 1. Member of the International Tax Planning Association (ITPA).
Marinos is specialized in International Tax Planning, Advanced Consulting, and Corporate Services.