TAX LAW, TAX PLANNING AND ADVANCED BUSINESS STRUCTURING

TAX LAW, TAX PLANNING AND ADVANCED BUSINESS STRUCTURING

Elias Neocleous & Co LLC has the largest and most experienced tax department of all Cyprus law firms, with an excellent reputation for high quality, sound tax advice and innovative tax planning, as well as extensive experience in negotiating and handling tax disputes.

Our clients are involved in a wide range of business activities, including property, finance, shipping, industrial, trading and energy.  We assist them with all aspects of cross-border development, from establishing their initial representative office to joint venture agreements and full-scale mergers and acquisitions.  Our tax specialists have extensive experience covering projects worldwide, particularly in Central and Eastern Europe, Asia and the Americas.  Through close co-operation with internal and external specialists in international tax law, we are able to assist our clients in structuring their international cross-border activities in the most tax-efficient manner. We offer specialist services in the following areas:

Tax advisory

Corporate tax advisory

  • Use of Cyprus-resident entities in global structures for investment, financing or other purposes
  • Corporate tax optimization
  • Obtaining advance tax rulings from the Cyprus tax authorities
  • Ongoing tax compliance
  • Restructurings, including mergers and acquisitions, takeovers, and transfers of seat from and into Cyprus
  • Advanced structuring to ensure eligibility for tax relief under domestic laws, double taxation agreements and EU directives
  • Transfer pricing         
  • Advice on new tax incentives and schemes, such as the notional interest deduction

Private wealth planning

  • Individual tax advisory and compliance
  • Advice on individual tax domicile and residency issues
  • Exchange of information under the Common Reporting Standard 
  • The Cyprus non-domiciled regime 
  • Tax efficient schemes and incentives for HNWIs such as yacht and aircraft leasing schemes and the use of trusts
  • Obtaining advance tax rulings from the Cyprus tax authorities
  • Exemptions and incentives available for individuals relocating to Cyprus

International Tax Planning in the new global environment

Our tax specialists keep abreast of all recent developments in the global tax planning sphere and can provide professional detailed advice on all matters including:- 

  • The OECD BEPS Initiative as implemented in Cyprus and its effect on existing and new structures
  • The new EU Parent Subsidiary Directive and other developments in the field of EU and international taxation
  • The proper interpretation and application of double taxation agreements, including the effect of anti-avoidance and anti-treaty shopping clauses;
  • The Common Reporting Standard (CRS) for automatic exchange of information
  • The implementation in Cyprus of the EU Anti-Avoidance Directives
  • The establishment of business and operational substance to meet the enhanced requirements of the new environment.

Advanced business structuring

Our firm offers specialist advice for the purposes of establishing and implementing efficient and robust corporate structures that will meet  all business, commercial and operational needs and comply with all local and international requirements in terms of business, management and infrastructural substance for tax purposes. Our team of experts can provide the following services:

  • Advising and assisting on the establishment of efficient corporate governance models
  • Advising and assisting with the identification of potential candidates to act as directors (executive and non-executive) with appropriate skills, expertise and experience 
  • Advising and assisting with the establishment of offices and corporate regional headquarters in Cyprus, and allocation of appropriately qualified human capital and other resources to corporate structures for operational purposes and tax optimization; 
  • Drafting and processing all necessary documents, directors’ appointment letters, employment agreements and other documents 
  • Assisting with the registration of the various officers and employees with the local authorities for social insurance, taxation and immigration law purposes
  • Provision of payroll, compliance and HR systems, or assistance with establishing in-house systems
  • Drafting and processing legal, corporate and commercial documents including lease agreements;
  • Performing legal due diligence in the context of acquisitions and corporate restructurings and establishment of headquarters
  • Assisting with registration of offices with authorities and utilities in Cyprus, including reviewing all necessary documents and attending to all necessary filings

 

Transfer pricing services

We can provide specialist advice and assistance on complex transfer pricing matters. Global organizations are operating in an environment of unprecedented challenges and changes. The increasing volume of intercompany transactions combined with more rigorous enforcement efforts on the part of tax authorities worldwide have made transfer pricing a substantial compliance priority for organizations engaged in cross-border transactions. Cyprus will be implementing detailed transfer pricing rules in 2017.

Our firm can help clients meet the new compliance requirements by introducing practical transfer pricing solutions into their overall global business operations and objectives, assist with the preparation of documentation to support their transfer pricing practices, and to represent clients before authorities and courts for the purposes of resolving disputes. In particular, in the context of the imminent implementation of transfer pricing rules in Cyprus, our team will be in a position offer specialist advice and assistance with the following matters:

  • Transfer Pricing Planning and Documentation

Our transfer pricing professionals can assist taxpayers with the preparation of comprehensive transfer pricing documentation and reports to reflect the commercial nature of their intra-group pricing strategies and decisions. We can also assist global groups to prepare cross-border documentation satisfying all of their documentation requirements in an efficient manner.

  • Advance Pricing Agreements (APAs)

Our transfer pricing professionals can assist clients with all aspects of supporting their transfer pricing strategies before the relevant tax authorities. We can also assist with applications for double tax relief through the tax treaty competent authority process and help clients submit applications to obtain Advance Pricing Agreements (APAs) with the tax authorities for the purposes of pre-agreeing and arriving at acceptable transfer pricing arrangements.

  • Dispute Resolution

We offer representation and professional assistance with disputes in relation to transfer pricing strategies.

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