Enhancing Substance

Substance in Cyprus is vital in order to:
  • support Cyprus tax residency status
  • avoid creating a taxable presence in another jurisdiction
  • support transfer pricing challenges
  • defend beneficial ownership challenges
  • address increased anti-avoidance and anti-abuse provisions
  • exchange information transparently and confidently

 
How CFA can help?

CFA specialists can assist you with the following services:

  • Diagnostics of the tax risks arising in the existing structure
  • Recommendations on the actions required to deal with these risks including aligning the following:
    • Split of functions and risks between foreign jurisdiction and Cyprus
    • Supporting of the desired functions and risks in the foreign jurisdiction and Cyprus with the corresponding substance in terms of decision-makers/employees’ location and documentation structure
  • Assistance in the implementation of substance recommendations following the diagnostic review
  • Assistance in preparing a comprehensive corporate governance framework
  • Setting-up an office and hiring employees in Cyprus (including assistance in drafting employment contracts, obtaining work permits and optimization of taxation and social security liabilities with respect to the employees)
  • Organization of decision-making process in relation to operational and strategic matters
  • Providing support in relation to administrative issues (assistance in accounting functions, tax compliance, audit) of the Cypriot companies

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