On 19 September 2018, the Cypriot Tax Department issued an announcement clarifying that Constituent entities with a Cypriot Ultimate Parent Entity (UPE) will not be subject to local filing in their jurisdiction of tax residency, given the relevant CbC Multilateral Competent Authority Agreement (MCAA) is activated between Cyprus and the other jurisdiction.
The Russian Ministry of Finance provides guidance on the dual tax residency status of individual tax payers.
The amended articles provide that the deadline for the submission of the personal income tax returns (T.D1s) for employees as well as for self-employees (who do note prepare audited financial statements) and the final tax payment for 2017 has been extended until 31 October 2018.
May 18th 2018: A Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income was signed between the Republic of Cyprus and the Principality of Andorra.
“Substance” is a well-known tax concept used in cross-border tax structuring. The term “substance” does not appear in the actual text of double tax treaties (DTTs).
The Russian courts issued a decision on 6 March 2018 (case OJSC SUEK-Kuzbass) on the application of the Double Tax Treaty between Cyprus and Russia of 1998 as amended in 2010 (the ‘DTT’). Based on the decision interest expense was considered as non-tax deductible in accordance with the Russian thin capitalization rules.
Personal taxes and contributions - The main types of direct taxes applicable to an individual in Cyprus are:Income tax; Special defence contribution on dividend, interest and rental income; Capital gains tax on gains from the sale of real estate situated in Cyprus
On 8 March 2018, the European Commission (EC) decided to send letter of formal notice to Cyprus. The EC held the view that the Cyprus VAT rules for the provision of yachts is incompatible with the EU VAT Directive (2006/112)