The current tax residency test in the Cyprus Tax Law continues to be the ‘management and control’ test which is satisfied if we are able to demonstrate that the majority of the directors are Cyprus resident and take decisions in Cyprus.
However, as the tax environment changes rapidly, we cannot predict if tax authorities will not adopt a similar stance with banks as to substance in the future and it is likely that the Cyprus tax residency of a company could be possibly challenged for trading companies that have failed to demonstrate real substance in Cyprus. Already, the banking authorities are calling for real substance in Cyprus in the form of actual presence and with various banking circulars stipulating that trading companies with no effective place of business and management, and hence no substance, will not be permitted to maintain bank accounts in Cyprus.
We at Parparinos Milonas Corporate & Legal Consultants believe that the existence of an office, facilities and employees in Cyprus is the key for establishing and enhancing substance. We are in a position to offer affordable substance solutions for businesses and organizations wishing to establish a prominent and professional presence complete with a corporate address, local telephone number, physical office rooms, boardroom, mail forwarding, receptionist and internet/IT infrastructure. Our clients are able to enjoy the benefits of a business presence in Cyprus at a minimum cost along with an overall business support solution to aid them in the day to day running of their business.
Our Law Firm provides assistance on a ‘case to case’ basis to clients who wish to enhance their presence in Cyprus and to build-up substance either by establishing themselves in Cyprus with a fully-fledged office and employees, or through other relevant means in order to adopt best practices, justify their tax-optimisation and eliminate any potential anti-avoidance rules. Listed below are the main features and benefits of our Substance Solutions:
- Fully equipped Office Rooms
- Large Meeting Room/Boardroom
- Fully Air-conditioned
- Copying, Printing, Scanning and Fax Services
- Free Internet Access
- Digital Document Storage
- Web Design & Development
- Personalized Stationery