CENTRAL EUROPE NORTH AMERICA EASTERN EUROPE MEDITERRANEAN active link OpusGuide Cyprus – Limited partnership (the “LP”) Cyprus has the lowest rate of income tax in the whole of the European Union. At the same time, the tax system provides for a range of exemptions including income from many sources, which may result in obtaining even lower tax rates. Amongst the extra benefits of registering a company in Cyprus, one could also mention the strategic position of the country, its wonderful infrastructure and the low cost of specialist services. Relationship Manager Tel. +357 24 62 99 62 [email protected] Limited partnership without separate legal personality registered under the CY Partnership Law, Cap.116 – Limited Partnership. LEGAL FORM POLISH EQUIVALENT SPHERE OF ACTIVITIES GOVERNING BODIES AND OTHER IMPORTANT POSITIONS / FUNCTIONS Małgorzata Michalska-Ioannou Limited partnership under the Polish law Any operational activities; no requirement to obtain permits (not a regulated activity). partners/owners At least one general partner who is liable for all the obligations of the LP and at least one limited partner, who is not responsible for the LP’s obligations beyond the amount he/she has contributed to the LP. management The management of the LP is conducted by the general partner(s) and in case of a conflict this is resolved by the majority of partners. supervisory There is no obligation to appoint a supervisory body; but it is permitted to do so. other The name of the partners are registered in the Registry of Companies (RoC); this information is publically available. nominee partner The economic owner(s) of the LP may act through a nominee partner within the institution of a Trust Deed (the Trust Agreement). The Cypriot laws secure a full anonymity. trust / fiduciary management The management is conducted through fiduciary services. USE OF TRUSTEESHIPS MINIMUM REGISTERED EQUITY No requirements for minimum registered equity. Contribution can be also made in labour. * data binding as of 28th April 2014 ACCOUNTING/AUDIT The LP is obliged to keep books of records; and if the turnover exceeds €70.000 per financial year, there is a requirement to prepare and file audited financial statements. HEADQUARTERS The LP is established and registered in the territory of Cyprus, and declared full details of the office / address upon the registration. TIMESCALES Establishment LP must be registered to the register of the RoC; failing to submit registration form to the RoC does not invalid the LP articles of association, however, penalties are available. Dissolution The LP can be registered for a fixed term or if entered into for an undefined time, the LP can be dissolved by any partner giving notice to other(s) of his/her intention to dissolve the LP. Strike-off The LP can file an application for a strike-off if it ceased its activities. BANK ACCOUNT NATIONAL CURRENCY No requirements to open a bank account in Cyprus. Euro OFFICIAL LANGUAGE Greek and Turkish. Internal company documentation may be written in English as well, including the LP articles of association. FINANCIAL YEAR In general, the financial year must be marked as 12 consecutive calendar months, however it may also be changed. INCOME TAX (CIT) LP, due to the fact of not having a legal personality, is not subject to the income tax. Following the principle of see-through approach, its income is taxed at the hands of partners, according to their participation in LP’s profit. The income of the partners is taxed accordingly to the tax implications in their tax residency jurisdiction. SPECIAL DEFENSE CONTRIBUTION TAX (SDC) SPECIAL TAX REGIME SDC does not apply to LP, since it is a see-through entity. Special tax regime should be checked at the level of partners. No special regimes for the LP. WITHOLDING TAX (WHT) Only royalties for the rights used in Cyprus are subject to withholding tax at the rates of 10% and 5% (in case of films). The rate may be reduced or exemption applied on the grounds of double tax treaties or an European Directive. ANTI-TAX -AVOIDANCE RULES Transfer pricing: NO transfer pricing in Cyprus (but arm’s length principle shall be applied). Thin capitalization: NO. CFC: NO. www.opus-net.eu
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