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Is a non resident Cyprus co. deriving most of its income/profit from cyprus based broker taxable?

Asked in Offshore (General) for Cyprus

0
Hi

Is this non resident Cyprus co.(with nominee directors that are Seychelles resident/citizens) deriving most of its income/profit from CFD trading from Cyprus based broker liable to pay ANY TAX (e.g CGT, Corporation tax etc) in Cyprus?

The company will have a Cyprus address as HQ mainly for receiving post. However management decisions and control of the company will happen probably from UK (how would you avoid breaching Controlled Foreign Company legislation and other anti-avoidance legislation)?.

 
Cyprus Legislation Tax Seychelles
 
Posted by Lowtax user on Jan 14, 2013 at 23:47
 

Comments

ROSE - My life was destroyed when my husband sent me packing, after 13 years we have been together. I was lost and helpless after trying so many ways to get my husband back to me. One day at work, I was distracted, not knowing that my boss called me, so he sat and asked me what it was all about, I told him and he smiled and said it was no problem. I never understood what he meant by it was no problem getting back my husband, he said he used a spell to get back his wife when she left him for another man, and now they are together till date and initially I was shocked hearing something from my boss. He gave me an email address of DR ODION, which helped him get his wife back, I never believed that this would work, but I had no choice coming into contact with the sayings that I get done, and he asked for my information and that my husband was able to propose to throw him the spell and I sent him the details, but after two days, my mother called me that my husband was pleading that he wants me back, I never believed, because it was just a dream and I had to rush off to my mother's place and to my greatest surprise, was kneeling my husband beg me for forgiveness that he wants me and the child back home, when I gave DR ODION a conversation regarding sudden change of my husband and he made clear to me that my husband will love me until the end of the world, that he will never leave for another woman. Now me and my husband is back together and started doing funny things he has not done before, he makes me happy and do what it is supposed to do as a man without nagging. Please if you need help of any kind need, please contact DR ODION for help. His email is (drodion60@yandex.com) or call +2347057623144 OR +2349060503921. Commented on Apr 04, 2017 at 10:35
ROSE - My life was destroyed when my husband sent me packing, after 13 years we have been together. I was lost and helpless after trying so many ways to get my husband back to me. One day at work, I was distracted, not knowing that my boss called me, so he sat and asked me what it was all about, I told him and he smiled and said it was no problem. I never understood what he meant by it was no problem getting back my husband, he said he used a spell to get back his wife when she left him for another man, and now they are together till date and initially I was shocked hearing something from my boss. He gave me an email address of DR ODION, which helped him get his wife back, I never believed that this would work, but I had no choice coming into contact with the sayings that I get done, and he asked for my information and that my husband was able to propose to throw him the spell and I sent him the details, but after two days, my mother called me that my husband was pleading that he wants me back, I never believed, because it was just a dream and I had to rush off to my mother's place and to my greatest surprise, was kneeling my husband beg me for forgiveness that he wants me and the child back home, when I gave DR ODION a conversation regarding sudden change of my husband and he made clear to me that my husband will love me until the end of the world, that he will never leave for another woman. Now me and my husband is back together and started doing funny things he has not done before, he makes me happy and do what it is supposed to do as a man without nagging. Please if you need help of any kind need, please contact DR ODION for help. His email is (drodion60@yandex.com) or call +2347057623144 OR +2349060503921. Commented on Apr 04, 2017 at 10:35

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Answers

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Please note the following ( for further explanations to at company formation - at 345 EURO - please email at enquiries@fbscyprus.com):

1. In Cyprus the worldwide profits of a company are taxable in Cyprus if the company is tax resident. This practically means management and control to be in Cyprus which means directors (majority) are cyprus tax residents AND BOD meetings take place in Cyprus. Operational day to day control (UK and Cy broker) do not amount to management and control. In conclusion if we have non resident directors in Seychelles and BOD meetings are held there then the company will be non resident and not taxed in Cyprus except on Cyprus source income. Maltese directors can also be used (EU directors more credible to tax authorities) as Malta does not tax then outside-of-Malta income of a Cyprus company managed from Malta- this is very popular for Cy NR cos.

2. In any case even if the co was a Cy tax resident company again the profits would be tax exempt as Cyprus exempts the profit or gain from sale of securities and derivatives of underlying securities from all taxes.

3. As far as avoiding uk cfc rules and anti-avoidance legislation we recommend the use of a Cyprus international trust to own the shares of the Cy co. Also as best practice dictates seek UK tax advice.

Contact us directly for more detailed discussions...
 
Posted by Lowtax User on Jan 17, 2013 at 08:59
 

Comments

ROSE - My life was destroyed when my husband sent me packing, after 13 years we have been together. I was lost and helpless after trying so many ways to get my husband back to me. One day at work, I was distracted, not knowing that my boss called me, so he sat and asked me what it was all about, I told him and he smiled and said it was no problem. I never understood what he meant by it was no problem getting back my husband, he said he used a spell to get back his wife when she left him for another man, and now they are together till date and initially I was shocked hearing something from my boss. He gave me an email address of DR ODION, which helped him get his wife back, I never believed that this would work, but I had no choice coming into contact with the sayings that I get done, and he asked for my information and that my husband was able to propose to throw him the spell and I sent him the details, but after two days, my mother called me that my husband was pleading that he wants me back, I never believed, because it was just a dream and I had to rush off to my mother's place and to my greatest surprise, was kneeling my husband beg me for forgiveness that he wants me and the child back home, when I gave DR ODION a conversation regarding sudden change of my husband and he made clear to me that my husband will love me until the end of the world, that he will never leave for another woman. Now me and my husband is back together and started doing funny things he has not done before, he makes me happy and do what it is supposed to do as a man without nagging. Please if you need help of any kind need, please contact DR ODION for help. His email is (drodion60@yandex.com) or call +2347057623144 OR +2349060503921. Commented on Apr 04, 2017 at 10:35

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In accordance with tax circular 2008/13 the profit will not be subject to Cyprus Corporation tax. With regards to the mgt and control should you choose for the Co to be considered as a Cyprus tax resident, obviously CTAs will not challenge it. That been as the Co's strategic decision are probably given from the UK (not from Seychelles and Cyprus) there is no way to avoid paying tax to the UK under local CFC rules. The only way to avoid is not to disclose your CY income and hope that will go under the radar of HMIR. Obviously this is not a serious tax strategy but this is what many investors choose to do, thus the reason for BEPS. Generally i wish you all the best and Merry Christmas
 
Posted by Commodum Audit Limited on Dec 23, 2015 at 21:25
 

Comments

ROSE - My life was destroyed when my husband sent me packing, after 13 years we have been together. I was lost and helpless after trying so many ways to get my husband back to me. One day at work, I was distracted, not knowing that my boss called me, so he sat and asked me what it was all about, I told him and he smiled and said it was no problem. I never understood what he meant by it was no problem getting back my husband, he said he used a spell to get back his wife when she left him for another man, and now they are together till date and initially I was shocked hearing something from my boss. He gave me an email address of DR ODION, which helped him get his wife back, I never believed that this would work, but I had no choice coming into contact with the sayings that I get done, and he asked for my information and that my husband was able to propose to throw him the spell and I sent him the details, but after two days, my mother called me that my husband was pleading that he wants me back, I never believed, because it was just a dream and I had to rush off to my mother's place and to my greatest surprise, was kneeling my husband beg me for forgiveness that he wants me and the child back home, when I gave DR ODION a conversation regarding sudden change of my husband and he made clear to me that my husband will love me until the end of the world, that he will never leave for another woman. Now me and my husband is back together and started doing funny things he has not done before, he makes me happy and do what it is supposed to do as a man without nagging. Please if you need help of any kind need, please contact DR ODION for help. His email is (drodion60@yandex.com) or call +2347057623144 OR +2349060503921. Commented on Apr 04, 2017 at 10:35

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My life was destroyed when my husband sent me packing, after 13 years we have been together. I was lost and helpless after trying so many ways to get my husband back to me. One day at work, I was distracted, not knowing that my boss called me, so he sat and asked me what it was all about, I told him and he smiled and said it was no problem. I never understood what he meant by it was no problem getting back my husband, he said he used a spell to get back his wife when she left him for another man, and now they are together till date and initially I was shocked hearing something from my boss. He gave me an email address of DR ODION, which helped him get his wife back, I never believed that this would work, but I had no choice coming into contact with the sayings that I get done, and he asked for my information and that my husband was able to propose to throw him the spell and I sent him the details, but after two days, my mother called me that my husband was pleading that he wants me back, I never believed, because it was just a dream and I had to rush off to my mother's place and to my greatest surprise, was kneeling my husband beg me for forgiveness that he wants me and the child back home, when I gave DR ODION a conversation regarding sudden change of my husband and he made clear to me that my husband will love me until the end of the world, that he will never leave for another woman. Now me and my husband is back together and started doing funny things he has not done before, he makes me happy and do what it is supposed to do as a man without nagging. Please if you need help of any kind need, please contact DR ODION for help. His email is (drodion60@yandex.com) or call +2347057623144 OR +2349060503921.
 
Posted by ROSE on Apr 04, 2017 at 10:35
 

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