INTERNATIONAL TAX PLANNING IDEAS

INTERNATIONAL TAX PLANNING IDEAS DINOS ANTONIOU C.E.O GLOBALSERVE GROUP

CYPRUS COMPANY AS A TRADING COMPANY EXPORT COMPANY IMPORT COMPANY • PROFIT IS TRANSFERRED TO CYPRUS AND TAXED AT 10% • SUBSTANCE IS IMPORTANT CYPRUS TRADING COMPANY

CYPRUS COMPANY AS INVESTOR IN ESTATE CO PROPERTY OWNED BY ESTATE CO ABROAD IS SOLD BY SELLING THE SHARES OF THE CYPRUS CO WHICH IS THE SOLE SHAREHOLDER OF THE ESTATE CO 0% TAX ON PROFIT FROM SALE OF SHARES OFFSHORE COMPANY HOLDING CYPRUS CO ESTATE CO ABROAD

CYPRUS COMPANY AS AN INVESTMENT COMPANY TRADING IN SECURITIES • PROFIT IS TAXEXEMPT • USE OF DOUBLE TAX TREATIES • NO WITHHOLDING TAX ON DIVIDENDS OUT OF CYPRUS CYPRUS CO TRADING IN SECURITIES BUY SECURITIES SELL SECURITIES

CYPRUS COMPANY AS A HOLDING COMPANY • NO WITHHOLDING TAX FROM DIVIDEND PAID FROM POLISH ( OR OTHER EU) SUBSIDIARIES AS PER PARENT SUBSIDIARY DIRECTIVE • ZERO OR LOWER WITHHOLDING TAX FROM NON EU TREATY SUBSIDIARY ( BASED ON DTT) • ZERO TAX IN CYPRUS ON DIVIDEND • NO WITHHOLDING TAX ON DIVIDEND PAID TO NON RESIDENT BY CYPRUS CO INCLUDING OFFSHORE COMPANIES ULTIMATE HOLDING CO CYPRUS HOLDING CO NON EU TREATY SUBSIDIARY POLISH SUBSIDIARY (EU CO)

CYPRUS COMPANY AS A FINANCE COMPANY • PROFITS REDUCED IN OPERATING COUNTRY DUE TO THE INTEREST PAID TO CY CO • SMALL INTEREST MARGIN TAXABLE AT 10% IN CYPRUS • NO WITHHOLDING TAX ON INTEREST OFFSHORE COMPANY CYPRUS FINANCING CO OPERATING CO

CYPRUS COMPANY AS A ROYALTY COMPANY Parent Co or Franchisor Plan: • Parent co establishes Cyprus royalty co to collect royalties from Polish co Benefits: • No WHT on royalty from Polish to Cy co • Tax on profit 10% in Cyprus on the net amount of the royalty income • Royalty is deducted from taxable profit in paying company • No WHT on royalty from Cyprus to the parent co or another franchisor Cyprus royalty Co 0 WHT 10% Operating Polish co 0 WHT

UNITED KINGDOM COMPANIES- Cyprus tax residents Most of our clients use UK Companies as non-UK residents because of the high tax rate in UK and elect to be Cyprus tax residents Management and control is in Cyprus As Cyprus tax resident, tax is paid in Cyprus and can enjoy all benefits of the extensive double tax treaties network of Cyprus but not of UK double tax treaties If VAT is needed then we incorporate a Cyprus branch at the Cyprus Registrar of Companies VAT registration is obtained the same day

ADVANTAGES VS DISADVANTAGES OF UK CO. RESIDENT IN CYPRUS ADVANTAGES • Taxed at a lower tax rate (the lowest in Europe) • Easier VAT registration procedure and requirements • Tax Authorities in Cyprus much less strict • Lower tax penalties • UK image can be used • Double Tax Treaty between Cyprus and Poland apply DISADVANTAGES • Cyprus network of DTT less extensive than UK • UK tax residence certificate cannot be obtained

Agency structure Offshore Principal Principal-Agent Agreement UK / CY Company Purchase Sale Goods Polish Company Buyer

LEGAL ASPECTS OF A CYPRUS INTERNATIONAL BUSINESS COMPANY • LIMITED COMPANIES • PARTNERSHIPS • BRANCHES • COMPANY INFORMATION FILED AT THE REGISTRAR • EASY REGISTRATION PROCEDURE • TO SERVE OUR CLIENTS BETTER AND QUICKER WE HAVE READY MADE ‘OFF THE SHELF COMPANIES’

REGISTRATION REQUIREMENTS • APPROVAL OF NAME • SHARE CAPITAL: MIN € 100 • SHAREHOLDER: AT LEAST ONE INDIVIDUAL OR COMPANY-NOMINEE SHAREHOLDER SERVICE • DIRECTOR: AT LEAST ONE CYPRIOT OR ALIEN- NOMINEE DIRECTOR SERVICE • SECRETARY: INDIVIDUAL OR COMPANY • REGISTERED OFFICE IN CYPRUS • AUDITED FINANCIAL STATEMENTS

SHAREHOLDING • BENEFICIAL SHAREHOLDERS CAN EITHER HAVE THE SHARES REGISTERED IN THEIR NAME AT THE REGISTRAR OF COMPANIES • OR CAN USE NOMINEE SERVICES I.E THE SHARES WILL BE HELD BY OUR NOMINEE COMPANIES IN TRUST FOR BENEFICIAL OWNERS TO ENSURE CONFIDENTIALITY

PROTECTION IN CASE OF NOMINEE SHAREHOLDERS • REPUTABLE NOMINEES • DECLARATION OF TRUST IS ISSUED BY THE NOMINEES • SIGNED INSTRUMENT OF SHARE TRANFER IS GIVEN BY THE NOMINEE TO THE BENEFICIAL OWNER • CONFIDENTIALITY IS SAFEGUARDED AS : • COPY OF THE PASSPORT IS HELD WITH US AND THE BANK ONLY • THE BANK DOES NOT DISCLOSE THE INFORMATION UNLESS IN CRIMINAL CASE

SUMMARY OF CYPRUS COMPANIES BENEFITS • LOWEST CORPORATE TAX RATE IN EUROPE – 10% • LOWEST VAT STANDARD RATE IN EUROPE – 15% • EASY VAT & TAX REGISTRATION PROCEDURES • EASY AND FAST OBTAINANCE OF TAX CERTIFICATES • THE BEST DTT WITH RUSSIA • LOW INCORPORATION & MAINTENACE COSTS • TRANSACTIONS WITH OFFSHORE JURISDICTIONS ARE FULLY ACCEPTED • SAME DAY OPENING OF BANK ACCOUNT • HIGHLY EFFICIENT BANKING OPERATIONS • PROFESSIONAL SERVICES OF HIGH STANDARDS • !!! BEAUTIFUL WEATHER !!!

GLOBALSERVE CONSULTANTS GLOBALSERVE CONSULTANTS IS THE FIDUCIARY/SERVICE PROVIDING COMPANY OF THE GROUP DINOS ANTONIOU & CO LTD (AUDITORS AND ACCOUNTANTS) WHY US ??? BECAUSE… • GLOBALSERVE PROVIDES FULL RANGE OF SERVICES INHOUSE THROUGH OUR EXPERIENCE TEAM OF ACCOUNTANTS, AUDITORS, TAX CONSULTANTS, LAWYERS AND CORPORATE OFFICERS, AS FOLLOWS : • TAX&FINANACIAL CONSULTANCY • FORMATION OF INTERNATIONAL BUSINESS COMPANIES (IBC) FROM 25 JURISDICTIONS • MANAGEMENT OF IBCs • OPENING AND OPERATING BANK ACCOUNTS IN CYPRUS & ABROAD • LEGAL&CORPORATE SERVICES, INCLUDING DUE DILIGENCE AND ESCROW SERVICES • ACCOUNTING&VAT SERVICES • FIDUCIARY/NOMINEE SERVICES • TRUSTS&TRUSTEES SERVICES • VIRTUAL OFFICE/ REAL OFFICES FOR RENT WITHIN THE GLOBALSERVE BUSINESS CENTRE • OFFICES PROVIDE SUBSTANCE TO THE CLIENTS’ COMPANIES • WEALTH ASSET MANAGEMENT VEHICLES E.G. FUNDS • AUDIT THROUGH OUR AUDITING FIRM DINOS ANTONIOU & CO LTD

GLOBALSERVE CONSULTANTS • LARGE NUMBER OF JURISDICTIONS OFFERED • CYPRUS COMPANIES • OTHER EUROPEAN JURISDICTIONS • UK, Dutch, Swiss, Malta, Denmark, Luxembourg, Liechtenstein etc • NON EUROPEAN JURISDICTIONS • Hong Kong, UAE, Singapore, etc. • OFFSHORE JURISDICTIONS • BVI, Belize, Delaware, Isle of Man, Seychelles, Panama, Marshall Islands, Mauritius Islands, etc. • SHELF COMPANIES FROM 10 JURISDICTIONS with apostil documents at our office for immediate use, including list of aged companies. • DIFFERENT NOMINEES OFFERED IN CYPRUS AND IN OTHER JURISDCTIONS: Physical or legal entities nominee directors/ shareholders/ secretary and registered office addresses to cater the needs of big groups • BANK ACCOUNT OPENING in one day in Cyprus and in many other countries in a short period of time through the network of banks for which we are approved introducers • EXPERIENCED IN THE MARKETS OF RUSSIA, UKRAINE AND THE CIS COUNTRIES SINCE 1994 • WE ARE A REGULATED COMPANY YOU CAN TRUST!!!

CONTACT US • GLOBALSERVE CONSULTANTS LTD • 9 VASSILI MICHAELIDES • 3026, LIMASSOL-CYPRUS • P.O BOX 57048, 3311, LIMASSOL, CYPRUS • TEL. 00357 25 817181, 00357 25 824545 • FAX. 00357 25 824055 • WEB SITE: www.globalserve.com.cy • EMAIL: info@globalserve.com.cy • CONTACT PERSONS: • DINOS ANTONIOU, C.E.O • PHANI SCHIZA ANTONIOU, MANAGING • DIRECTOR

THANK YOU

INTERNATIONAL TAX PLANNING IDEAS