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Considering the ever intensifying initiatives around the world against superfluous establishments and the Base Erosion and Profit Shifting (BEPS) project by the OECD, the need to adopt the correct structure, with adequate resources in relation to the type and volume of business activities, becomes more imperative than ever before.
Cyprus remains an attractive jurisdiction for companies setting up European headquarters, due to its low rate of corporation tax, its favourable reliefs/credits on certain activities, and due to its infrastructure and skill set. Substance describes the various characteristics, which demonstrate that the company does indeed operate in the country where it is a tax resident and is not merely a "shell" company formed to avoid paying (usually much higher) tax in their home country.
The taxation of Cyprus companies is based on residence. All companies that are tax residents in Cyprus are taxed on their worldwide income accrued or arising from sources both within and outside Cyprus. Non-resident companies are taxed in Cyprus only on income derived from a permanent establishment or immovable property in Cyprus. A company is resident of Cyprus if it is managed and controlled in Cyprus. However, the main principle is that the registration or incorporation of such a company in Cyprus is not sufficient to render the company liable to tax in Cyprus.
If an international corporation implements substance, it can lead to significant benefits including the minimization of chances for disputes concerning the purpose of the operation by foreign tax, and other authorities.
Material substance may include:
Our Cyprus law firm AMG Mylonas & Associates, LLC is offering to our clients’ a unique all-encompassing Cyprus company set-up – European headquarters service for a very competitive fixed fee.
Benefits of choosing Mylonas Law to set up your Cyprus company structure:
With this uniquely priced service, clients get all the benefits of Cyprus – European headquarters with significantly reduced costs.
Establish a professional presence in Cyprus with AMG Mylonas Law virtual office service. Our service includes a virtual office space and address in a prime location in the center of Limassol, on Agias Filaxeos Avenue, call answering and mail handling services so that you run your business as smoothly as possible.
At AMG Mylonas Law, we believe that globalization is the key to a successful business. Despite your location, you can establish a corporate presence for your business without the expenses that come from renting an office space or hiring employees. Virtual Office Services provides the services and infrastructure to run your business professionally at a minimal cost.
A virtual office is a combination of off-site live communication and address services that allow users to reduce the standard office costs whilst maintaining business professionalism. Having in mind that a newly incorporated business may not have the initial capital as typically required in the business sector, we can assure that we provide virtual office services at an affordable fee. We look after all your business administration requirements, so that you can concentrate on what you do best in business. We provide offshore companies with an office space as well as all the services they need to take their small business to the next level, or downsize in an instant, launch a new venture, take on a temporary project or make your meetings more productive.
With our Virtual Office service, you will receive all the tools required to overcome the competition: a receptionist to answer phone calls, a corporate business address for all your mail, a voice inbox and fax number that will convert to email, and much more.
A Virtual office is the gist of your business and illustrates your effort to go offshore with the rewards being evident/remarkable. A Virtual Office is easy to set up and lacks nothing compared with other countries, where it may be obligatory to pay exorbitant fees, costs, taxes, etc.
A company that can demonstrate that it has substance, management, and control in Cyprus, can more easily claim the benefits of DTTs and take advantage of the favorable Cyprus tax regime unlike with corporations who do not have substance.
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