Back to loans cyprus tax department
Following a number of amendments to Cyprus tax legislation, there have been significant changes to the Study Guide . The amendments to legislation are a result of measures to combat tax evasion and to increase government revenue, as well as new incentives to make the tax system more attractive. In a previous article, ‘Amendments to the Paper P6 (CYP) syllabus’, I listed the main changes and gave a brief description of each. In certain cases, I stated that a technical article will be issued to help explain the change.
This article is the second in a series written for this purpose and expands on points A3(b) and (c) of the aforementioned article. It explains the tax treatment of back-to-back loans as well as an amendment relating to the deductibility of loan interest when the loan is used to purchase shares in a 100% subsidiary of a Cyprus company. Candidates will be expected to be familiar with the provisions stated within this technical article, although no references to circulars or sections of tax legislation are required.
(a) Tax years 2003–2007
For the tax years 2003 until 2007 inclusive (ie from 1 January 2003 until 31 December 2007), the minimum profit margin acceptable on back-to-back loans, regardless of the amount of the loan, is 0.3%.
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