Cyprus Casino resort is ready to go by Melco International Development and Hard Rock International

Melco and Hard Rock have now the green light to build the mammoth casino resort in the coastal town of Limassol. The Cyprus casino will include 136 gambling tables and 1,200 gambling machines, whilst the adjoining hotel will have a 500-room capacity, a health spa and a 1,500-seat concert hall

The project is ready to start since the license has already been awarded. The project is estimated to cost half a billion Euros and is expected to be completed by first half of 2020

This is the largest project tourism-related investment ever built in Cyprus that is set to attract around 300,000 additional tourists annually

The Cyprus Tax Department has issued a circular for the tax treatment of intra-group financing transactions (Cyprus transfer pricing rules on intra-group financing transactions). The term intra-group financing transaction (transfer pricing rules on intra-group financing transactions) refers to any activity consisting in the granting of loans, debentures, or cash advances remunerated by interest to related companies (Related companies are defined as the relationship between two companies for instance that of holding company and subsidiary company or the relationship between associated companies where there is control on the composition of board of directors, holding the majority of the voting rights etc)
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New Cyprus tax incentives for persons wishing to transfer their tax residence to Cyprus

Individuals can transfer their tax residence to Cyprus if they are not considered tax residents in any other state

In particular, an individual may now be considered a tax resident in Cyprus if he is not considered a tax resident of any other state and if he does not remain in that other country for more than 183 days in the relevant fiscal year. The individual should also not be….

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The new Cyprus tax incentive aims to support new Cyprus enterprises in the development of innovative products and services and to strengthen the Cypriot business ecosystem. The Cyprus taxation incentive is in line with EU rules on state aid, as outlined in the EU Regulations 651/2014.

Eligibility for the Cyprus taxation incentive

According to the Cyprus law a “qualifying investor” that makes a “risk-finance investment” in an “innovative small and medium-sized enterprise (SME)” may deduct the costs of the investment from his/her taxable income, subject to the following limitations:

Percentage Limit: The tax deduction is limited to 50% of the investor’s taxable income in the year in which the investment is made,
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Under the double taxation agreement between Cyprus and Russia, profits from sale of shares are taxable only in the country of residence of the person who owns the shares. Cyprus does not impose capital gains tax on sales of shares (unless they own immovable property in Cyprus) and therefore these profits are exempt from tax.

A new protocol came into effect in 2013 providing that gains from the disposal of shares in companies holding immovable property are subject to taxation in Russia as of 1 January 2017

Implementation of the protocol has been postponed until Russia agrees with other EU countries, therefore sale of shares of companies holding immovable property in Russia will continue to be exempt from tax. Anything else regarding the double taxation agreement remained unaffected

Cyprus Passport (Cyprus Citizenship by investment) is currently considered as one of the most attractive passport in Europe. Investment required can be as low as 2 Million Euros

Cyprus Passport (Cyprus Citizenship by investment) criteria

The applicant should:

1. Invest in Cyprus 2 Million Euros plus VAT where applicable over the last 3 years. The investment should be held for at least 3 years. Investment can be in either or a combination of:….

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The Cyprus Visa (Investment Permanent Residency Program),Cyprus visa, is the most popular and most attractive to foreign investors. It compares the most favorable among all other investments immigration programs offered by other countries.

Cyprus government decided to simplify and shortened the process to obtain Cyprus visa making it very attractive to foreign investors. In order for the government to issue immigration permit to applicants, who are third country nationals, they must fulfill the following criteria:

1. MINIMUM ANNUAL INCOME OF €30,000

The applicant must prove…
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Over the past years, Cyprus was developed into one of the most favorable places for international business. The Cyprus low tax regime combined with Cyprus excellent geographical position, infrastructure and Cyprus ability to offer sophisticated planning structures, the ability to set up and manage Investment Funds (Cyprus Alternative investment funds – AIFs), the enactment of the Cyprus International Trusts Law which provided for the formation and administration of international trusts ,the excellent geographical position, infrastructure and good quality of life, the recent developments like the construction of luxurious Marinas, the decision to build a mammoth casino resort by year 2020 and its excellent infrastructure in banking and telecommunication where some of the key factors for its success.

Cyprus is now encouraging High-net worth individuals moving to Cyprus by giving personal taxation incentives and benefits

Individual’s most important Cyprus taxation advantages and benefits when moving to Cyprus:

+ An individual can become Cyprus tax resident and obtain a Cyprus Tax Identification number (TIN) within a short period of time;

+ A Cyprus tax resident individual by obtaining the Cyprus non domicile resident status is totally exempt from Cyprus taxes on dividend, interest and rental (property situated in Cyprus) income;
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Cyprus is now encouraging High-net worth individuals to move to Cyprus by giving personal taxation incentives

The introduction of “Domicile” regime aims to exempt High-net worth non-domiciled individuals moving to Cyprus from personal taxes (Special Contribution for Defense). High-net worth non-domiciled individuals (non-doms) will need to declare Cyprus as their taxable jurisdiction and receive an exemption from Cyprus personal taxes (Special Contribution for Defense) on rents (3% on 75% on rent income), interest (30%) and dividends (17%) which are applicable to Cyprus domiciled individuals.The exemption will apply for 17 years as from the date of declaring Cyprus as their taxable jurisdiction.
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There have been significant discussions around the world on taxpayers’ methods of minimizing taxes. Expressions like:

• beneficial owner,
• economic substance
• management and control,
• place of effective management,
• resident,

have been triggering discussions throughout the world as they are closely related with people’s tax minimisation.
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PKF Cyprus Tax Guide 2017 provides comprehensive and up to date information to Cyprus Companies and Individuals on Cyprus tax system and on Cyprus Tax rates, such as personal income tax, corporate tax, capital gains tax, immovable property tax, VAT rates, immovable property transfer fees, etc. In addition PKF Cyprus Tax Guide can be a useful reference in general and Cyprus tax planning.
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Over the years PKF Nicosia, Cyprus partners and staff have participated and contributed in the structuring of Multinational Companies (MNCs) and High Net Worth Individuals (HNWIs) including inter alia the proper allocation of Multinationals group risks, on the choice between capitalizing a business enterprise with debt or equity, on finance companies and payments in respect of loans between foreign companies, on intellectual property rights etc.
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