Chancellery’s offices in Cyprus
Our direct presence in Cyprus allows us to minimize the activities of intermediaries. This increases the quality level of the services offered, as well as shortens and improves the service process.
The law firm thus provides greater control over the implementation of each stage of international tax planning, while optimizing the costs associated with establishing a company, accounting services, obtaining tax residence, etc. An additional advantage of opening our offices in these countries is, among others, the possibility of constant monitoring of changing regulations there and direct contact with officials.
The presence of the Law Firm’s representatives in Cyprus also allows for establishing new business contacts with institutions such as banks and consulting companies. Thanks to the increased freedom of action, our offer is not limited to intermediation in customer-agent relations. We are the local adviser.
Change of tax residence
This solution is dedicated to natural persons, but is not the same as changing citizenship. It is associated only with a change of the jurisdiction in which taxes are paid and does not always have to be associated with literal emigration.
The most frequently chosen tax residences are Cyprus and Maltese. Depending on the jurisdiction you choose, certain conditions for obtaining tax residence must be met.
Interpretation of the CFC regulations should take into account the essence of the primary source of income for a foreign company
In order to recognize the company as a Controlled Foreign Company (CFC), it should be shown why the income of the foreign company from participation in unincorporated companies falls under the category of passive income.
Therefore, it should also be explained why, for the assessment of the revenues of a foreign company as subject to CFC taxation, the decisive factor is the classification of revenues at the level of partnerships in which the company has a share in the profits, and not at the level of the company itself – ruled the Supreme Administrative Court , overruling the judgment of the provincial administrative court dismissing the complaint of a Polish tax resident against the interpretation of the Minister of Finance, recognizing a Cypriot company in which it holds 100% of shares as a foreign controlled company (judgment of the Supreme Administrative Court of 9 July 2019, file ref. II FSK 2522/17 ).