Long Awaited Removal from the Russian Black List Achieved

The long awaited removal of Cyprus from the Russian Ministry of Finance's list of designated offshore jurisdictions, also known as the “Black List” has finally been achieved. With effect from January 2013, Cyprus will become a much more attractive jurisdiction for both inbound and outbound investments by Russians and for third country nationals from a tax planning and transfer pricing perspective.
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Most Positive Developments
Dividend Payments
Dividends received by Russian companies from their Cypriot subsidiaries will be exempt from taxation in Russia (Article 284, Clause 3(1) of the Tax code). This is provided the recipient has held not less than a 50% equity share in the Cypriot subsidiary for a continuous duration of at least 365 days. To date, and prior to the removal of Cyprus from the Black list, such dividends were taxed in Russia at a rate of 9%.

Transfer Pricing
Transactions between Russian and Cypriot entities will no longer be subject to transfer pricing control in Russia (Article 105.14, Clause 1(3) of the Tax code).The standard pricing regulations will continue to apply.
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How Amicorp Can Assist
Russian and multinational companies should consider whether these changes can be exploited to achieve a more favorable tax-efficient structure using Cyprus.

Amicorp, in cooperation with globally recognized professional intermediaries and tax consultants, may proceed to evaluate the current structure of your business and propose new structuring opportunities, their implementation, and management.

For further information about using Cyprus Ltd. companies for your structuring requirements, please contact your nearest Amicorp office or Amicorp Cyprus directly.
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For more information contact:

Elia Nicolaou
Amicorp Cyprus

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