INTERNATIONAL BUSINESS COMPANIES
- IBCs will be considered as tax residents and taxed in accordance
with the above corporation tax rates in the case where they are managed
and controlled in Cyprus
- IBCs will be entitled to the new beneficial tax provisions.
- IBCs are now entitled to derive income from Cyprus sources. (Necessary
permits must be obtained).
- IBCs will be subject to the Social Cohesion Fund Law and will be
required to contribute at the rate of 2% over the gross emoluments
of all its tax resident employees working in Cyprus.
- 50% of the interest income will be exempted from corporate tax
but the whole amount of interest income will be subject to Special
contribution at the rate of 10%. Interest from normal trading activities
such as banking and finance activities is considered as trading income
and taxed at the normal prevailing corporation tax rates.
- Dividend income from overseas companies is exempted provided that
the Cyprus recipient company owns at least 1% of the shares of the
investing company. This exemption is only available in the case where
the paying company’s activities is more that 50% of investing
nature and the governing tax jurisdiction is not substantially lower
that that of Cyprus. (The present Laws encourages the setting
up of International Holding Companies)
- IBCs are totally exempted from the Defense Fund levy on dividend
or on deemed dividend distribution provisions.
- Profits from operations from a permanent establishment abroad are
completely exempted. This exemption is not granted where the permanent
establishment directly or indirectly engages in more than 50% of its
activities in producing investment income and the governing jurisdiction’s
tax rate is substantially lower than that of Cyprus.
- IBCs holding royalty rights will be outside the scope of withholding
tax scheme on royalties’ payable if the right is granted for
use outside Cyprus.
- Profits from trading in securities and other derivatives are exempted
from Income Tax. (This will encourage the establishment of Collective
Investment Schemes).
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