Monthly Archive for: ‘June, 2012’

Back to back loans for Cyprus companies

  Back to back are loans which the Cyprus tax resident company borrows, and in turn, lends this amount to related parties. This arrangement is widely favored by international companies which use a Cyprus company to redistribute their profits, leaving a small profit margin in Cyprus. The ultimate shareholders of all the companies involved must be non-tax residents. A Cyprus …

Read More

The Double Tax Treaty (DTT) Protocol between Cyprus and Russia

  Following the ratification of the DTT Protocol between Cyprus and Russia, Cyprus has officially been removed from Russia’s “black list” of offshore jurisdictions meaning that dividends received by Russian companies from Cyprus subsidiaries can qualify for the Russian dividend participation exemption. The participation exemption provides that dividends received by a Russian company from an overseas subsidiary are tax free …

Read More