2. Cyprus: general advantages
The most attractive jurisdiction within EU: no tax for dividends, interest and
royalties, tax exemption on capital gains, transfer or sale of the shares, etc.
One of the lowest corporate tax rate within EU (12,5%) along with a wide
network of double tax treaties and other tax benefits, provide a significant reduction
of tax burden.
Professional & Nominee services:
very competitive cost of professional financial services along with high quality of
business services make Cyprus one of the most successful business centers within
EU.
Cyprus company could be an efficient tool, for instance, to following purpose:
- business structuring and asset protection;
- trading and brokering operations;
- IP licensing / sublicensing agreement management.
3. Belize: general advantages
Classic offshore jurisdiction. In Belize, you can register tax-exempt companies -
International Business Companies (IBC). International Business Companies are not
allowed for trade or own real estate within Belize, and not allowed to engage in
banking or insurance.
Short deadlines for registration, ready-made companies (shelf companies) for
speedup the process of structuring the holding.
Low cost for registration, annual service and maintenance.
International Business Companies can be an effective tool in international trade and
investment, also for:
- holding companies structuring;
- registration of rights to intellectual property;
- financing and lending to subsidiaries.
4. Holding Structure Belize-Cyprus:
efficient tax planning tool
IBC
BELIZE
LTD or PLC
CYPRUS
ASSET 2 ASSET 3ASSET 1
Beneficiary
Corporate tax – 0%
Withholding taxes:
- dividends – 0%
- interest – 0%
- royalties – 0%
Private or Public company in Euro zone;
Corporate tax – 12,5%
Dividends tax exemption
No withholding taxes
Capital gain and income tax exemption from
operations with securities
A wide network of
double tax treaties
with more than
50 countries
5. Holding Structure Belize-Cyprus:
high level of confidentiality of business ownership
IBC
BELIZE
LTD
CYPRUS
Nominee Director
Nominee Shareholder
Management through a trust
agreement with a Cypriot company
Bank account in Europe or in Asia
Internet banking services
Dual degree of confidentiality
Nominee Director
Nominee Shareholder
Corporate secretary
Management through a trust
agreement with a Cypriot company
Bank account in Cyprus or in Switzerland
Internet banking services
Applying Nominee Director and Nominee Shareholder provides a high degree of
confidentiality of ownership and business management
6. Holding Structure Belize-Cyprus: dividend payment
Example of dividend payment from Russia:
The Cyprus company owns stake / shares of Russian company. *
The Belize company owns the shares of Cyprus company.
CYPRUS
BELIZE
* The investment of at least EUR 100 000
5%
0% 0%
0%
15% 0%
withholding
tax
withholding
tax
on
receive
on
receive
withholding
tax
on
receive
Double Tax Treaty
Agreement
NO
Double Tax Treaty
Agreement
RUSSIA
Swiss Bank Account
7. Holding Structure Belize-Cyprus: royalty, interest payment
Example of royalty payment from Russia:
Company in Belize has the right to the trademark and has the license agreement on using trademark with
Cyprus company. Cyprus-based company provides the right for using trademark by sub-license to the
Russian company with regular royalty payment.
CYPRUS
BELIZE
0%
0%
20% 0%
withholding
tax
on
receive
withholding
tax
on
receive
Double Tax Treaty
Agreement
RUSSIA
VAT VAT
12,5% - corporate tax on difference
between the received and paid
royalties
If the difference between
received and paid
royalties=1%,
the effective tax burden is
only 0.125%
deduction
NO
Double Tax Treaty
Agreement
Swiss Bank Account
8. Business Structuring & Asset Protection:
contemporary solutions
SHF.M. ADVISORS LTD:
Actual solutions to structure and protect your business and assets, trustee services and management,
professional tax planning and inheritance programs.
All you need for your business with our professional support in Cyprus and other reputable jurisdictions.
Please contact us for more information about our services:
Phone: +357 25 030 505
Fax: +357 25 030 511
E-mail: customer@shfm-advisors.com
www.shfm-advisors.com