Tax on corporate transactions in Cyprus: overview

A Q&A guide to tax on corporate transactions in Cyprus.

The Q&A gives a high level overview of tax in Cyprus and looks at key practical issues including, for example: the main taxes, reliefs and structures used in share and asset sales, dividends, mergers, joint ventures, reorganisations, share buybacks, private equity deals and restructuring and insolvency.

To compare answers across multiple jurisdictions, visit the Tax on corporate transactions Country Q&A tool.

The Q&A is part of the Multi-jurisdictional Guide to Tax on Transactions. For a full list of jurisdictional Q&As visit www.practicallaw.com/taxontransactions-mjg.

Elias Neocleous and Philippos Aristotelous, Andreas Neocleous & Co LLC
Contents

Tax authorities

1. What are the main authorities responsible for enforcing taxes on corporate transactions in your jurisdiction?

There are two relevant departments within the Ministry of Finance:

  • The Inland Revenue Department (IRD) administers direct taxation (broadly, income tax, corporation tax, capital gains tax (CGT), special defence contribution (SDC)) and stamp duty. Tax collection is organised through district offices.

  • The Department of Customs and Excise administers VAT through the VAT Service. Day-to-day VAT collection and administration is organised through district offices.

A law was passed in mid-2014 to merge the IRD and the VAT Service. The merger is expected to be complete before the end of 2014.

Pre-completion clearances and guidance

2. Is it possible to apply for tax clearances or obtain guidance from the tax authorities before completing a corporate transaction?

There is no statutory or formal extra-statutory clearance procedure. However, by convention, the Director of the IRD provides written replies on the interpretation of the taxation statutes and, provided the enquiry fully discloses all relevant facts, these replies are potentially binding on the IRD as a matter of public law.

 

Main taxes on corporate transactions

Transfer taxes and notaries' fees

3. What are the main transfer taxes and/or notaries' fees potentially payable on corporate transactions?

Stamp duty

Stamp duty is a tax on documents similar to UK stamp duty. A stampable document (broadly, a contract, wherever created or executed, governing a transaction relating to property in Cyprus or anything done in Cyprus) which is not stamped with the correct amount of duty paid cannot be adduced in evidence in court without payment of the duty and appropriate penalty.

The stampable contracts most frequently encountered in corporate transactions include:

  • Share purchase agreements.

  • Asset purchase agreements.

  • Joint venture agreements.

  • Subscription and shareholder agreements.

  • Debentures.

Rates of stamp duty are as follows:

  • On transactions with a consideration of up to EUR5,000 no stamp duty is payable.

  • On transactions with a consideration of between EUR5,000 and EUR170,000, stamp duty of EUR1.5 for every EUR1,000 (or part of EUR1,000) is payable.

  • On transactions with a consideration in excess of EUR170,000, stamp duty of EUR2 for every EUR1,000 (or part of EUR1,000) is payable.

Where no amount of consideration is specified in the contract the stamp duty is EUR35. The maximum stamp duty payable on a contract is capped at EUR20,000. For a transaction which is evidenced by several documents, stamp duty is payable at the usual rate on the main contract and ancillary documents are charged at the flat rate of EUR2.

A number of categories of documents are exempt from stamp duty, including documents relating to corporate reorganisations (which are exempt from all forms of taxation) and ship mortgage deeds or other security documents.

Stamp duty must be paid within 30 days from the date of execution of the relevant documents or, if they are executed abroad, within 30 days after they are received in Cyprus. If stamp duty is paid late, a surcharge of approximately 10% of the unpaid amount is payable provided payment is made within six months after the due date. Otherwise, the surcharge for later payments is twice the unpaid amount.

Stock transfer fees

Stock transfer fees are payable by corporate entities selling shares quoted on the Cyprus Stock Exchange (CSE) at 1% of sale proceeds.

Land transfer fees

Land transfer fees are payable by a corporate buyer or donee of real property in Cyprus when title deeds are issued by the Department of Land and Surveys.

Land transfer fees are charged at progressive rates on successive tranches of the acquisition price (or market value of gifts) as follows:

  • Up to EUR85,000: 3%.

  • EUR85,000 to EUR170,000: 5%.

  • Over EUR170,000: 8%.

Corporate and capital gains taxes

4. What are the main corporate and/or capital gains taxes potentially payable on corporate transactions?

Overview

Taxation payable by companies in Cyprus on typical corporate transactions is generally confined to transfer and other indirect taxes.

Corporation tax may arise on the sale of goodwill and intellectual property rights (IPRs) and CGT may arise on the sale of Cyprus immovable property (whether directly or indirectly on the sale of shares in a property holding company).

An overview of the taxation of companies is provided below.

Corporation tax

A company is resident in Cyprus if it is managed and controlled in Cyprus.

Corporation tax is assessed by reference to the calendar year at a flat rate of 12.5%, on the worldwide taxable profit of a company resident in Cyprus and on the Cyprus-source profits of non-resident companies with a permanent establishment (PE) in Cyprus.

Taxable profits include:

  • Trading profit, which includes profits from the sale of:

    • goodwill;

    • IPRs;

    • work in progress;

    • stock.

  • Interest earned within or closely related to the ordinary course of business.

  • Rents from real estate.

  • Royalties.

The major reliefs available are:

  • Expenditure wholly and exclusively incurred in earning the taxable income.

  • Capital allowances.

  • Credits for foreign tax paid.

  • Losses surrendered in the same year by other companies in a 75% group relationship.

  • Unused losses brought forward from previous years. Trading losses may be carried forward for a maximum of five years.

No corporation tax is payable by a company in relation to:

  • Profits or gains from the sale of securities (widely defined).

  • Dividend income (which is generally exempt from all tax in Cyprus but may be subject to SDC; see below, SDC).

  • Interest other than interest received within or closely related to the ordinary course of business of the company (which is subject to SDC at 30% of the gross amount; see below, SDC).

  • Capital gains (but see below, CGT on disposals of immovable property).

A favourable tax regime is available to shipping and ship management companies under which tax liabilities are calculated by reference to revenues or tonnage of vessels, at the taxpayer's option.

In 2012, Cyprus introduced an "intellectual property box" regime which provides a deduction equal to 80% of income from intellectual property assets and consequently an effective tax rate of less than 2% on such income. Gains on disposal are effectively tax exempt.

SDC

SDC is imposed on Cyprus residents only.

Dividends. Dividend income of individual Cyprus residents is liable to SDC at a rate of 17%. Companies are exempt from SDC on dividends received unless at least one of the following applies:

  • The dividend income is paid by a non-resident company bearing a significantly lower tax burden than that imposed in Cyprus (in practice, 5% or below), more than 50% of the activities of which result directly or indirectly in passive investment income (the "passive dividend" rules).

  • A Cyprus-resident company fails to distribute at least 70% of its net distributable profits within two years of the end of the year in which this profit was earned. In this case, its Cyprus-resident shareholders are deemed to receive their proportionate share of the dividend, which is charged to SDC at 17% (or 3% for collective investment schemes), withheld and accounted for by the company. This charge can be avoided by ensuring the company distributes 70% of its income within the two-year time frame and it applies only where the shareholder concerned is a Cyprus tax resident and to the extent that the ultimate shareholders are Cyprus tax resident.

  • Notwithstanding the 70% distribution threshold for avoiding the SDC charge, SDC is payable at 17% (or 3% for collective investment schemes) on any dividends paid four years or more later than the year the underlying profits were generated. This applies only where the shareholder concerned is a Cyprus tax resident and to the extent that the ultimate shareholders are Cyprus tax resident.

Interest outside the ordinary course of business. Interest received outside the ordinary course of business of the company is subject to SDC at 30% on the gross amount of interest received. It is therefore advisable to ensure that a company lends money only within the ordinary course of its business, which is accepted to include the capitalisation of subsidiaries by holding and finance companies.

CGT on disposals of immovable property

CGT is imposed at 20% on all gains (regardless of the residence of the disponor) from both:

  • Disposals of immovable property situated in Cyprus.

  • Disposals of shares of companies holding immovable property situated in Cyprus (charged on the appropriate portion of the gain).

Capital losses can be carried forward.

Value added and sales taxes

5. What are the main value added and/or sales taxes potentially payable on corporate transactions?

Value added tax (VAT)

The standard rate of VAT is 19%. Reduced rates of 5% and 9% apply to certain services.

VAT is administered on broadly the same principles across the EU member states, and is consequently potentially chargeable on the sale of assets, subject to the exemption for transfers of a going concern.

Sales of shares are generally exempt supplies, and as such, no input tax incurred on related costs such as professional fees can be recovered. However, following the ECJ decision in Kretztechnik AG v Finanzamt Linz (Case C-465/03), input tax incurred in connection with the issue of shares is generally recoverable.

Other taxes on corporate transactions

6. Are any other taxes potentially payable on corporate transactions?

Capital duty

Capital duty is payable at 0.6% of the authorised share capital of a Cyprus-registered company, both on incorporation and on any increase in authorised share capital.

Capital duty can be mitigated by creating shares at a lower nominal value and higher premium.

Taxes applicable to foreign companies

7. In what circumstances will the taxes identified in Questions 3 to 6 be applicable to foreign companies (in other words, what "presence" is required to give rise to tax liability)?

Indirect taxes

Non-residents are generally liable for indirect taxes in Cyprus (see Question 3, Stamp duty and Land transfer fees, and Question 5).

Direct taxes

A non-resident company is liable to corporation tax on:

  • Rents from immovable property in Cyprus.

  • Business profits attributable to a PE in Cyprus (see below).

  • Profits on the sale of goodwill.

A non-resident company is generally treated as having a PE in Cyprus if it maintains a fixed place of business or management or has a dependent agent acting on its behalf in Cyprus. An offshore drilling or production facility may also constitute a PE.

No PE is created by an independent agent acting within the ordinary course of its business or a representative office of a non-resident company.

A non-resident company is also liable to:

  • CGT on gains arising from the disposal of immovable property in Cyprus.

  • Capital duty in the case of a Cyprus-registered non-resident company.

A non-resident company is not liable to SDC.

 

Dividends

8. Is there a requirement to withhold tax on dividends or other distributions?

SDC (see Question 4, SDC) must be withheld by Cyprus companies on dividends paid to Cyprus-resident shareholders at a rate of 17%. There is no withholding requirement on dividends paid to non-residents.

 

Share acquisitions and disposals

Taxes potentially payable

9. What taxes are potentially payable on a share acquisition/share disposal?

Stamp duty

This is payable on a share purchase agreement or other contracts relating to the disposal of shares in a Cyprus company (see Question 3, Stamp duty).

Stock transfer fees

This is payable on the disposal of CSE-listed shares (see Question 3, Stock transfer fees).

CGT

If the target company owns immovable property in Cyprus, CGT is payable on any gain attributable to the property (see Question 4, CGT on disposals of immovable property) unless reorganisation relief is available (see Question 26).

Exemptions and reliefs

10. Are any exemptions or reliefs available to the liable party?

The CGT potentially payable on the sale of shares in a target company holding immovable property in Cyprus, as well as stamp duty charges, are relieved in full if the transfer takes place as part of a reorganisation (see Question 26).

Tax advantages/disadvantages for the buyer

11. Please set out the tax advantages and disadvantages of a share acquisition for the buyer.

Advantages

Historic losses are carried forward in the target company for up to five years to reduce future taxable profits.

No VAT arises on the sale of shares.

Disadvantages

Among the liabilities of the target company acquired, the buyer may inherit undisclosed tax liabilities.

Tax advantages/disadvantages for the seller

12. Please set out the tax advantages and disadvantages of a share disposal for the seller.

Advantages

The exemption from corporation tax in relation to transactions in securities (see Question 4, Corporation tax) can be used to shield the seller from tax on the profit arising on the sale of goodwill and IPR.

Disadvantages

Capital losses incurred on the disposal of shares cannot be used.

Transaction structures to minimise the tax burden

13. What transaction structures (if any) are commonly used to minimise the tax burden?

The Cyprus tax code is intentionally straightforward and the approach of the tax authorities is generally favourable to taxpayers.

Consequently, structuring transactions involving Cyprus companies (which almost invariably feature a cross-border element) typically focuses on the tax codes of other relevant jurisdictions.

 

Asset acquisitions and disposals

Taxes potentially payable

14. What taxes are potentially payable on an asset acquisition/asset disposal?

Stamp duty

This is payable on asset purchase agreements and other relevant documents (see Question 3, Stamp duty).

Land transfer fees

This is payable on the acquisition of immovable property in Cyprus (see Question 3, Land transfer fees).

Corporation tax

Intangible assets. A seller is potentially subject to corporation tax on gains from the disposal of goodwill and intellectual property. The gain on goodwill is calculated by deducting the cost from the disposal proceeds. Profits from the disposal of intellectual property are treated as trading income for corporation tax purposes.

Capital allowances balancing charge. If the consideration attributed to an asset on the disposal of a business exceeds its tax written down value after deduction of capital allowances (see Question 15, Corporation tax: Capital allowances), the excess is subject to corporation tax in the hands of the corporate seller.

Stock and work in progress. Sums from the disposal of trading stock or work in progress are treated as trading income for corporation tax purposes, in the hands of the corporate seller.

Trade debtors. If the amounts subsequently collected from trade debts exceed the price paid for those debts, the excess is treated as profit chargeable to corporation tax in the hands of the buyer of the debts.

Foreign company PE. A foreign company PE is liable to pay corporation tax on gains arising on the disposal of assets used in carrying out its trade.

Transfer pricing. Cyprus operates a basic transfer pricing regime, which adjusts the profits of a business to include profits which would otherwise have accrued to it had arrangements with its connected parties been made at arm's length.

CGT

This is payable on any gain arising from the disposal of immovable property in Cyprus or shares in companies holding such property (see Question 4, CGT on disposals of immovable property).

VAT

VAT is generally chargeable on a supply of business assets, unless the disposal is a transfer of a business as a going concern (see Question 5).

Other taxes

Capital duty is chargeable on any increase in authorised share capital to allow the issue of consideration shares (see Question 6).

Exemptions and reliefs

15. Are any exemptions or reliefs available to the liable party?

Corporation tax

Reorganisation relief. Taxes arising on a sale of assets to a company in exchange for the issue of shares can potentially be relieved in full (see Question 26).

Capital allowances. A buyer of business assets is entitled to annual capital allowances of:

  • 10% or up to 25% on qualifying expenditure on certain IT equipment, plant and machinery.

  • 4% for industrial buildings from first use of the building.

  • 3% for commercial buildings.

Capital allowances are claimed on a straight-line basis.

Accounting amortisation tax relief. A buyer who is within the charge to Cyprus corporation tax (including a foreign company PE) can claim relief on the acquisition cost of second-hand cargo and passenger ships.

Capital allowances balancing allowance. If the consideration attributed to an asset on the disposal of a business is less than its tax written down value (see above), the shortfall can be offset against the seller's trading income to reduce its corporation tax.

Trading stock. A tax deduction may be available to a buyer for sums paid for stock, provided such stock is appropriated to its trading stock.

Allowable losses. Current year, surrendered and carried-forward losses can be offset against income arising on the sale of a business, provided neither the ownership of the company nor the nature of the trade have significantly changed. Current year and brought-forward CGT losses can be offset against a capital gain from the disposal of real estate in Cyprus as part of the business.

Asset base cost step-up. As the buyer effectively acquires a market value base cost in the taxable assets, the profits from a subsequent disposal of the asset are calculated by reference to the increase in value after the business acquisition.

VAT

If a corporate seller transfers its business or part of it as a going concern to a buyer intending to use the assets to carry on the same kind of business, the supply generally falls outside the scope of VAT. Further, the land and building element of such a sale is outside the scope of VAT (see Question 3, Land transfer fees).

Tax advantages/disadvantages for the buyer

16. Please set out the tax advantages and disadvantages of an asset acquisition for the buyer.

Advantages

Key advantages of an asset purchase arise when significant allowances are available as follows:

  • Capital allowances and depreciation relief for the cost of assets purchased.

  • The immediate tax deduction of any amount paid for stock.

  • The potential acquisition of a market value base cost.

Disadvantages

Trading losses are not automatically transferred with the business and assets.

Tax advantages/disadvantages for the seller

17. Please set out the tax advantages and disadvantages of an asset disposal for the seller.

Advantages

An asset sale may allow a seller to:

  • Use carried forward corporation tax and CGT losses.

  • Trigger balancing allowances.

  • Take advantage of a dividend exemption on extraction of the profits of sale.

Disadvantages

An asset sale can trigger several tax charges in the hands of the seller (see Question 14) which do not typically arise on a share sale.

Transaction structures to minimise the tax burden

18. What transaction structures (if any) are commonly used to minimise the tax burden?

Where the commercial rationale for an asset sale is the need to sell a branch or discrete profit centre, the potential tax charges on an asset sale (see Question 14) can often be avoided, by hiving the relevant assets down to a newly formed subsidiary in exchange for the issue of consideration shares which are then sold.

Careful planning is required to ensure the hive-down qualifies for reorganisation relief (see Question 26) and general anti-avoidance rules are not used to recharacterise the transaction as an asset sale.

 

Legal mergers

Taxes potentially payable

19. What taxes are potentially payable on a legal merger?

Stamp duty

This is payable on contracts documenting a merger (see Question 3, Stamp duty).

Land transfer fees

These are payable on transfer of immovable property in Cyprus (see Question 3, Land transfer fees).

Corporation tax

This is potentially payable in relation to transfers of assets (see Question 14).

CGT

This is payable on any gain arising from the disposal of immovable property in Cyprus or shares in companies holding such property (see Question 4, CGT on disposals of immovable property).

VAT

VAT is generally chargeable on a supply of business assets, unless the disposal is a transfer of a business as a going concern (see Question 5).

Other taxes

Capital duty is chargeable on any increase in authorised share capital to allow the issue of consideration shares (see Question 6).

Exemptions and reliefs

20. Are any exemptions or reliefs available to the liable party?

Reorganisation relief from CGT, corporation tax and stamp duty is available, provided the merger falls within the statutory definition of reorganisation (see Question 26).

Transaction structures to minimise the tax burden

21. What transaction structures (if any) are commonly used to minimise the tax burden?

Structures should be carefully planned to take advantage of reorganisation relief (see Question 26).

 

Joint ventures

Taxes potentially payable

22. What taxes are potentially payable on establishing a joint venture company (JVC)?

Stamp duty

This is payable on the joint venture agreement (see Question 3, Stamp duty).

Land transfer fees

These are payable on transfer of immovable property in Cyprus (see Question 3, Land transfer fees).

Corporation tax

This is potentially payable in relation to transfers of assets (see Question 14). Transfer pricing adjustments may be made (see Question 14).

CGT

This is payable on any gain arising from the disposal of immovable property in Cyprus or shares in companies holding such property (see Question 4, CGT on disposals of immovable property).

VAT

VAT is generally chargeable on a supply of business assets, unless the disposal is a transfer of a business as a going concern (see Question 5).

Other taxes

Capital duty is chargeable on any increase in authorised share capital to allow the issue of consideration shares (see Question 6).

Exemptions and reliefs

23. Are any exemptions or reliefs available to the liable party?

The scope for reducing taxation on the formation of the JVC is limited. However, if part of the transaction can be structured to fall within a defined reorganisation, reorganisation relief from CGT, corporation tax and stamp duty is available (see Question 26).

VAT is not chargeable on the transfer of a business as a going concern.

Capital duty can be mitigated by creating shares at a lower nominal value and higher premium.

Transaction structures to minimise the tax burden

24. What transaction structures (if any) are commonly used to minimise the tax burden?
 

Company reorganisations

Taxes potentially payable

25. What taxes are potentially payable on a company reorganisation?

Stamp duty

This is payable on contracts documenting the transaction (see Question 3, Stamp duty).

Land transfer fees

This is payable on the transfer of immovable property in Cyprus (see Question 3, Land transfer fees).

Corporation tax

This is potentially payable in relation to transfers of assets (see Question 14).

CGT

This is payable on any gain arising from the disposal of immovable property in Cyprus or shares in companies holding such property (see Question 4, CGT on disposals of immovable property).

VAT

VAT is generally chargeable on a supply of business assets, unless the disposal is a transfer of a business as a going concern (see Question 5).

Other taxes

Capital duty is chargeable on any increase in authorised share capital to allow the issue of consideration shares (see Question 6).

Exemptions and reliefs

26. Are any exemptions or reliefs available to the liable party?

Reorganisation relief is available to allow the following transactions to take place in a broadly tax-neutral manner, with exemption from corporation tax and stamp duty:

  • Merger. This involves:

    • transfer on dissolution of all assets and liabilities from one company to another;

    • transfer by two companies to a third company, in exchange for the issue of shares (and limited cash amount); or

    • transfer on dissolution of all assets and liabilities to a 100% parent, without the transferring company or companies going into liquidation.

  • Demergers. Transfer on dissolution of all assets and liabilities by a company to two or more companies, in exchange for the pro-rata issue of shares to the members of the transferring company.

  • Transfer of assets. Transfer of any number of discrete branches, divisions or other profit centres to another company, in exchange for the issue of shares to the transferring company.

  • Exchange of shares. Acquisition of a majority voting stake in a company, in exchange for the issue of shares in the acquiring company.

A disposal of shares or conversion of securities is generally exempt from corporation tax.

Transaction structures to minimise the tax burden

27. What transaction structures (if any) are commonly used to minimise the tax burden?
 

Restructuring and insolvency

28. What are the key tax implications of the business insolvency and restructuring procedures in your jurisdiction?

Business insolvency and restructuring procedures have relatively few tax implications.

Tax implications for the business

There are no tax implications for the business.

Tax implications for the owners

On dissolution of a Cyprus-resident company, other than as part of a reorganisation (see Question 26), its Cyprus-resident shareholders are liable to account for SDC at 17% on a deemed distribution, consisting of the cumulative profits of the previous five years which have neither been distributed nor previously deemed distributed. For collective investment schemes the SDC rate is reduced from 17% to 3%.

Tax implications for the creditors

Creditors are entitled to deduct bad debts from trading profits for corporate income tax purposes and to recover VAT on bad debts.

 

Share buybacks

Taxes potentially payable

29. What taxes are potentially payable on a share buyback? (List them and cross-refer to Questions 3 to 6 as appropriate.)

SDC

Cyprus corporate law allows public companies to redeem preference shares and repurchase up to 10% of their own issued shares out of distributable profits, or to return capital to shareholders under a court approved capital reduction.

When capital is returned to a Cyprus-resident shareholder in a capital reduction, this gives rise to a deemed distribution chargeable to SDC at 17%, relating to amounts returned or due to shareholders up to the amount of undistributed taxable income of any previous or current tax year (before carried forward losses but net of previous deemed distributions) (see Question 4, SDC). (For redemption of units in collective investment schemes the SDC rate is reduced from 17% to 3%.)

Exemptions and reliefs

30. Are any exemptions or reliefs available to the liable party?

Not applicable.

Transaction structures to minimise the tax burden

31. What transaction structures (if any) are commonly used to minimise the tax burden?

Not applicable.

 

Private equity financed transactions: MBOs

Taxes potentially payable

32. What taxes are potentially payable on a management buyout (MBO)?

The taxes payable on a standard share or asset sale apply equally to MBOs (see Questions 9 to 18).

The personal income tax position of managers receiving equity incentives requires careful planning.

Exemptions and reliefs

33. Are any exemptions or reliefs available to the liable party?

Cyprus has no thin capitalisation rules. Although there is scope for challenging excessive interest deductions under the transfer pricing regime (see Question 14), in practice adjustments are made only to artificially high interest rates on debt finance.

There is significant scope in Cyprus to reduce or eliminate tax in the MBO vehicle and potentially to surrender losses to the target company by group relief.

Transaction structures to minimise the tax burden

34. What transaction structures (if any) are commonly used to minimise the tax burden?

As MBOs using Cyprus companies typically feature a cross-border element, structuring transactions involving Cyprus companies focuses on the tax codes of other relevant jurisdictions.

 

Reform

35. Please summarise any proposals for reform that will impact on the taxation of corporate transactions.

The government has recently announced a proposal to merge the Inland Revenue and VAT departments into one, in order to improve efficiency. The process is expected to be complete by the end of 2014.

 

Online resources

Inland Revenue Department

W http://www.mof.gov.cy/mof/ird/dmllaws_gr/dmllaws_gr?OpenDocument

Description. Inland Revenue Department containing Greek language text of legislation and circulars. The Greek language text is binding.

Ministry of Finance

W http://www.mof.gov.cy/mof/mof.nsf/page26_en/page26_en?OpenDocument

Description. List of double taxation agreements, which is regularly updated.



Contributor profiles

Elias Neocleous

Andreas Neocleous & Co LLC

T +357 25 110000
F +357 25 110001
E info@neocleous.com
W www.neocleous.com

Qualified. Admitted to Bar, Inner Temple, London, 1992; Admitted to Cyprus Bar, 1993

Areas of practice. M&A; banking and finance; international taxation; corporate and structured finance; restructuring and insolvency.

Recent transactions

  • Advising the endowment fund of one of the world's most respected universities on the structuring of a US$125 million international investment.
  • Advising a major international bank on the most efficient methods of repatriating profits accumulated in a Cyprus company.
  • Advising on the corporate reorganisation of a company listed on the Budapest and Warsaw Stock Exchanges, with operations in Hungary, Poland and several other Eastern European countries.
  • Advising leading global organisations on the Cyprus law and tax aspects of internal reorganisations.

Philippos Aristotelous

Andreas Neocleous & Co LLC

T +357 25 110000
F +357 25 110001
E info@neocleous.com
W www.neocleous.com

Qualified. Admitted to Bar, Inner Temple, London, 2004; Admitted to Cyprus Bar, 2005

Areas of practice. M&A; banking and finance; international taxation; trusts; corporate and structured finance; restructuring.

Recent transactions

  • Advising on the establishment of a segregated investment fund of US$200 million dealing in forestry land and carbon credits.
  • Providing legal and tax advice on a major restructuring of a household-name UK company with substantial intellectual property assets involving several onshore and offshore jurisdictions.
  • Advising on the establishment of a Cyprus collective investment scheme as a master feeder vehicle in the form of a limited partnership and on investment by CIS-based investors into Cyprus funds in the context of the applicability of the Cyprus - Belarus double tax treaty to a limited partnership.

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