Cyprus Company Formation, Holding Cyprus, Cyprus Investment Firm, Offshore Company Formation
Company Formation Cyprus: Services
- Index company formation cyprus
- Tax planning via a network of international tax advisers and attorneys
- Offshore Company Formation: Tax haven rankings
- Cyprus Holding
- Examples for the legal reduction of corporate taxes
- DTA permanent establishment concept –Our services and fees
- Parent companies and their subsidiaries in the European Union
- OECD: Articles of the Model Convention with Respect to taxes on income and on capital
- Beware of cheap founders!
- Basic considerations within the framework of international taxation
Company Formation Cyprus:
Company formation Cyprus: Services for complete packages (full service)
The following services are included in our complete packages:
Forming of the company, entry in the commercial register of the country, apostille, notarially certified translations of certificates into English, unless official language
- Nominee director: An attorney in the formation country will act as nominee director of the company (to the outside) and transfers all rights and obligations internally to the actual beneficiary (notarial deed of trust). The director does not have any account authority.
- Nominee shareholder: a tax office in the formation country will act as nominee shareholder (to the outside) of the company and transfers all rights and obligations internally to the actual beneficiary (notarial deed of trust).
- Domicile of the company in the formation country: deliverable postal address, availability by telephone, telephone and fax, mail forwarding service
- Account opening: bank account for the company at a renowned major bank in the formation country, internet banking, VisaCard and cheques. Only the founder of the company is authorized to have access to the account.
- General power of attorney to the founder: Only the founder receives a notarially certified general power of attorney for the company.
- Recommendation of a renowned tax office in the formation country, for book-keeping and accounting
- Internet-homepage of the company hosted on a server in the formation country: 5 pages for presentation of services/products, feedback form, imprint, e-mail address. May be extended at any time.
Company formation Cyprus: Our Services within the scope of the Formation Package “Cypriote Limited”
- Please note that our formation package contains the tax identification number and the value added tax ID number, accounting, annual financial statement, as well as the preparation of the annual return and advance turnover tax returns. As such, the otherwise substantial fees associated with a Cypriote tax accountant do not apply (of course your collaboration is required: Presorting of the invoices, cash journal, bank statements etc…) In addition, our formation packages contain:
- Account opening in Cyprus and Delivery and Shipping Service for letters / invoices!
- Formation / Consulting by Tax Accountants and Attorneys at Law
- No “Formation Director” or “Formation Shareholder” Moreover a Cypriot is the Director; the Director is registered and is reachable during the entire agreement term. Provision of Nominees via a Cypriote Law Firm, no “Figurehead Directors”.
- No “Help with the opening of a bank account” on Cyprus (which as a rule means that an account is not opened) rather guaranteed account opening, incl. VisaCard and online banking. You do not have to travel to Cyprus.
- Serviceable postal address, also for registered mail, no post office box
- Upon request free within the scope of the total package: Swiss company and / or personal account at a major Swiss private bank. Our clients are not required to open a branch office in Switzerland, to open a company account in Switzerland, (otherwise a prerequisite). A Swiss account could, for example, be used to “securely park and multiply” Cypriote dividends.
Stock Capital: The recommended authorized capital amount is CYP£ 1,000, unless you wish to commit a larger amount. The business of the company is not restricted to the amount of the authorized capital. The minimum amount of authorized stock capital for the registration of a Ltd. is CYP£ 1,000. In the event, however, the company opens an office in Cyprus (commercially structured organization), the minimum amount is CYP£ 10,000. We would like to point out the fact that this amount does NOT have to be blocked on Cyprus.
Company formation Cyprus: Configuration at the Formation of a Cypriote Limited
1. Director on Cyprus
A production site, a site for the exploitation of mineral resources or construction works whose duration is greater than 9-12 months always constitutes the establishment of a place of business in Cyprus, irregardless of “the place of managerial supervision”. Otherwise a taxable permanent establishment is defined analogous to Article 5 DBA (Double Taxation Agreement) according to the “place of managerial supervision”. Either you – or an agent – relocate your ordinary residence to Cyprus and act as the Director of the Cypriote Limited OR you hire a Cypriote as a Director OR our Law Firm in Cyprus provides for a Nominee Director. By the way, we also provide the possibility to our clients, that a Cypriot acts as an “employed Director” of the Cypriote Limited, with an employment agreement between the Cypriote Limited and the Director, as well as the payment of payroll tax and social security contributions.
Alternative: The non-Cypriote client / founder himself acts as the Director of the company and provides proof that he routinely travels to Cyprus to perform the required ordinary managerial duties (however, this is not feasible in the case of the necessary day-to-day decisions).
2. Shareholder of the Cypriote Limited
The shareholder is due the profits after taxes (dividends). In addition, the shareholder is the owner of the company. Shareholders of a Cypriote Limited can be natural persons, or domestic or foreign companies.
In the event a Cypriote is a shareholder a 15% defense tax is due, when the dividends are distributed or if no dividends are distributed for a period of two years. For this reason we offer a „Nominee Shareholder“ within the scope of our services, more specifically our English Tax Accounting Firm acts as the Nominee Shareholder.
Cyprus provides the advantage, that dividend distributions to a non-Cypriote is not taxed. There are exceptions to this arrangement, which we would like to explain in more detail in a personal setting.
To the extent the client / founder or his company would like to act as the shareholder himself, the following factors are to be observed:
Does your country have laws analogous to the „taxation of fictitious distributions“, comparable to those in Germany and the USA? Such laws result in the Cypriote dividends being taxed at the shareholder, even if they are not distributed. This is subject to the prerequisites, that the client / founder owns more than 50% of the shares (majority shareholder) and the Cypriote Limited located on Cyprus only generates passive income. In the event such laws exist within the European Union, this is illegal, based on the findings of the European Court of Justice.
If this is the case, the client / founder should “officially” only hold a maximum of 50% of the shares, the other shares should be held on a trust basis.
Does the EU-Parent-Subsidiary- Directive apply? In the event the shareholder is a company located in the EU and should the company hold at least 15% of the shares of the Cypriote Limited and both companies (Cypriote Limited and Shareholder) are active companies and the interest is evidently set up for at least one year, then the dividends are distributed tax free to the foreign shareholder due to the EU Parent Subsidiary Directive.
A Danish corporation is the 100% shareholder of a Cypriote Limited. The Cypriote Limited is first taxed at a 10% rate. The dividends (earnings after taxes) distributed to the Danish corporation are tax free. Such dividends are first taxed in the event they are distributed to the shareholder of the Danish corporation, provided such shareholder is an individual.
Please consider, that it is not mandate of a Cypriote Limited to distribute dividends. Moreover, the Cypriote Limited can make investments across the globe, for example: purchase a house in Spain.
Company Formation Cyprus: Comparative Overview of Services:
|Lawyer’s office in Cyprus takes charge of setting up the company||YES||Not as a rule|
|Tax arrangements through tax consultants specialising in international tax law*||YES||Not as a rule|
|Proper registered office can be set up**||YES||Not as a rule|
|Essential “documentation” required to be presented in accordance with Cypriot law are provided free of charge (Draft contracts, free agreement, staff contract, accounting documentation etc…)||YES||Not as a rule|
|A trust director can be appointed who will sign contracts on behalf of the company***||YES||Not as a rule|
|Swiss deposit account included in the package free of charge||YES||Not as a rule|
|If setting up an agency or a branch office out with Cyprus and trust services: carried out by the director of the Cypriot limited company ****||YES||Not as a rule|
|Opening of an account in Cyprus guaranteed, client does not need to travel to Cyprus***||YES||NOT the case with many “agencies”|
|Certificate of residence from the Cypriot tax office in the case of trust services****||YES||NO|
|Setting up of an offshore company as a shareholder of the Cypriot limited company in order to conceal the true circumstances surrounding ownership (if a trust shareholder is not desired), at the same time “G20-proof”||YES||Not as a rule|
|Bookkeeping, VAT registration, annual accounts, tax consultants are English-speaking||YES||Frequently not the case|
|EU merger-directive measures, that is with regard to the merging of companies, for example||YES||Not as a rule|
* In the case of most providers what is involved are agencies that simply set up companies, that is ones with no tax consultants specialising in international tax law.
**Proper registered office: merely having a registered office and/or “letter-box” is not a proper place of business in this sense. ETC will set up a virtual office up to and including the provision of a reasonable office solution in Cyprus on request.
***Most providers only appoint a trust director who does not sign any contracts on behalf of the company outwith the statutory regulations. There is hereby a risk that must be assumed that the senior management of the company is not located in Cyprus (5 DTA: location of the senior management as the location of the business premises provided that there is no production facility in Cyprus, no construction work lasting longer than 6-9 months or a site for the exploitation of mineral resources in Cyprus).
**** ETC guarantees the opening of an account in Cyprus. The client does not need to travel to Cyprus in order to open the account.
**** The competent tax office for the client can demand a certificate of residence from the Cypriot tax office in order to guarantee that what is involved in the case of the Cypriot company is not just a sham company in this sense (an intermediary company in order to illegally get out of being subjected to domestic taxation).
Company Formation Cyprus: Offices – Nicosia Jacovides Tower
Jacovides Tower is a stylish modern building in the business district, five minutes from the centre of Nicosia, with many banks, government offices, ministries, clinics and embassies in the area. Nicosia is the largest city in Cyprus and part of the prosperous Greek Cypriot economy. Cyprus has an open, free-market, service-based economy with some light manufacturing. Its capital is a trade centre and manufactures textiles, leather, pottery, plastic, and other products, with copper mines nearby. The city is also the seat of the University of Cyprus and four other universities. Nicosia’s economic development focuses on services, tourism, and high-technology. The government is working to make Cyprus a regional hub of advanced telecommunication services. One project involved a submarine fibre-optic cable system through Cyprus connecting to Israel, Syria, Lebanon, Egypt, and Greece.
- City/Town centre
- Major transport links
- 24 hour access
- Business Lounge
- Meeting Rooms
- Lounge area
- Disabled facilities
- Videoconferencing studio
- Vending Machines
- Smoking Areas