Thus, a substantial number of companies involved in the trading or distribution of FMCG and other physical goods use Cyprus as a trading base for the Mediterranean, Middle East and North African region. Non-resident enterprises (ie those neither ‘managed and controlled’ nor with a local permanent establishment) are allowed to store, maintain, break bulk or re-package their own transit goods in bonded warehouses, providing the handling doesn’t result in any change of customs’ tariff classification. They are also permitted to conduct sales activities on the island, as long as no local deliveries result, and no permanent establishment is created.
Cyprus is not a particularly convenient offshore base for supplying the CIS and Eastern Europe in physical terms, but that does not prevent companies with interests in those regions from establishing holding companies in Cyprus, and very many do so. Not only are the Cyprus treaty withholding tax rates normally lower than those in other countries’ treaties, but there will be no local taxation as long as no permanent establishment is created, and even if it is, Cyprus’s own 10% tax rate on company profits is itself low. The combination is quite hard to beat;
Along with other low-tax jurisdictions, Cyprus is a suitable place in which to base e-commerce services for retail or wholesale distribution of material or non-material goods.
Published by Lowtax.net
