The Google search of “Cyprus company“ gives the outcome such as “Cyprus: Tax Heaven”, “tax benefits of Cyprus”, etc. Cyprus but also other traditional holding jurisdictions like the Netherlands or Luxemburg are deemed to be tax heavens and are automatically connected with the aggressive tax planning or the tax avoidance.
However, on certain conditions holding companies in these jurisdictions are fully legitimate. We covered this topic on the Conference on international taxes organised by the Slovak Chamber of Tax Advisors in cooperation with AmCham Slovakia and IFA.
Issues covered:
- Tax residence of the company as defined in the Slovak Income Tax Act
- Definition of the place of effective management under the Slovak ITA
- Definition of the beneficial owner in Slovak law
- Interpretation of these terms under the Double Tax Treaties
- Case law of the Court of Justice of the EU
- Case studies
Panelists: Jozef Danis, SKDP, Renáta Blahova, IFA