The future of international Tax planning and International

The future of international Tax planning and International Banking Christodoulos Kourtellaris Legal Aspects of Investing in Ukraine and European Jurisdictions IBC Legal Services 2019

CONTENTS ü The Multilateral Instrument ü The EU Anti Tax Avoidance Directive ü Exchange of Information Update ü Transfer pricing requirements in Cyprus-existing and new legislation ü Substance and tax residency for companies

MULTI-LATERAL INSTRUMENT TREATY SHOPPING TREATY ABUSE IMPLEMENTATION

MULTI-LATERAL INSTRUMENT TREATY SHOPPING TREATY ABUSE IMPLEMENTATION In June 2017 under the OECD BEPS initiative, 68 countries (including Cyprus, Russia and Ukraine but not the USA) signed the Multi-lateral instrument (MLI), which will implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. • Subsequently more countries signed the MLI bringing the total of signatories to 87. • On 22 March 2018, the OECD announced that the MLI will enter into force on 1 July 2018, following the deposit of the ratification instrument by a fifth jurisdiction. • By the end of October 2019 36 countries deposited the ratification instruments with the OECD. • These countries include a number of Cyprus treaty partners (highlighted below). • These countries include: Australia, Austria, Curacao, Finland, France, Georgia, Guernsey, Ireland, the Isle of Man, Israel, Japan, Jersey, Lithuania, Malta, Monaco, Netherlands, New Zealand, Poland, Serbia, Singapore, Slovakia, Slovenia, Sweden the UK, Ukraine. •

Multi-lateral instrument The MLI offers concrete solutions for governments to close the gaps in existing international tax rules by transposing results from the BEPS project into their bilateral tax treaties by: • Modifying the application of thousands of bilateral tax treaties concluded to eliminate double taxation • Implementing agreed minimum standards to combat treaty abuse • Improving dispute resolution mechanisms • Providing flexibility to accommodate specific tax treaty policies

Multi-lateral instrument The MLI covers the following subjects: • Hybrid mismatches • Treaty abuse • Avoidance of permanent establishment status • Improving dispute resolution • Arbitration Most countries have elected to deal only with the Treaty Abuse provisions

Position of Cyprus on the MLI • Cyprus extended the application of the MLI to the 55 individual treaties signed by Cyprus, plus three treaties covered under the old treaty with the Republic of Yugoslavia (Bosnia and Herzegovina, Montenegro and Serbia) plus three treaties covered under the old treaty with the USSR (Azerbaijan, Kyrgyzstan and Uzbekistan) • No tax treaties of Cyprus have been excluded

Key information on MLI • MLI - Multilateral Convention to implement Tax Treaty related measures to prevent Base Erosion and Profit Shifting (“BEPS”). Developed on the basis of Action 15 of OECD BEPS Action Plan. • BEPS Action Plan – 15 actions developed by OECD and G 20 to equip governments to address tax avoidance, ensuring that profits are taxed where value is created. Purpose • Swift implementation by governments of measures strengthening doubletax treaties protecting governments against tax avoidance strategies that inappropriately use tax treaties to artificially shift profits to low or no-tax jurisdictions. Entry into force • MLI entered into force on 1 July 2018. Signatories • 90 signatories as of 30 October 2019. For Ukraine MLI enters into force on 1 December 2019. Definition • Covered Tax Agreement (“CTA”) means an agreement for the avoidance of double taxation (“DTT”) with respect to tax on income (. . . ): (i) which is in force between two Parties; and (ii) with respect to which each Party has made a notification listing the agreement as well as any amending or accompanying instrument thereto (. . . ) as an agreement which it wishes to be covered by the Convention.

Key information on MLI ENTERS INTO FORCE TWO DTTS ARE CTA • The MLI provisions for a particular CTA enter into force: as of the latest date on which MLI enters into force for each Contracting Jurisdictions AND with respect to taxes withheld at source (from the 1 st day of the next calendar year) / with respect to all other taxes (as of expiration of a period of 6 months). • For both Contracting Jurisdictions for which MLI has entered into force (i. e. both parties to a CTA have deposited their ratification instruments with the OECD Secretariat) AND For both Contracting Jurisdictions which listed the respective DTT in their MLI position as Covered Tax Agreement. • PROVISIONS MATCH • CTA will be changed if there is a match between reservations and optional provisions selected by both parties.

MLI provisions HYBRID MISMATCHES TREATY ABUSE ARTIFICIAL AVOIDANCE OF PE STATUS IMPROVEMENTS TO DISPUTE RESOLUTION Neutralization of negative effect of hybrid mismatch arrangements (transparent and dual resident entities). Preventing granting of treaty benefits in inappropriate circumstances. Rethinking of commissionaire and similar arrangements to prevent the artificial avoidance of PE status. Resolving disputes concerning application/interpretation of CTA by mutual agreement procedures.

MLI, treaty abuse PREAMBLE, TREATY ABUSE PREAMBLE Source: Changes to the preamble to emphasize that DTTs are not intended to be used to generate double non-taxation (art. 6 MLI). Key outcome: Elimination of double-taxation without giving opportunities for tax evasion or avoidance (including through treaty-shopping arrangements). “Intending to eliminate double taxation with respect to the taxes covered by this agreement without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this agreement for the indirect benefit of residents of third jurisdictions). ” TREATY ABUSE Source: Changes ensuring protection from treaty-shopping (art. 7 MLI) Key outcome: • PPT: a GAAR denying the benefit of a DTT (clear ); or • Detailed LOB and a mechanism to deal with conduit arrangements not already dealt with in the LOB provision; or • Combined approach with a simplified LOB or detailed LOB, and PPT.

Principal Purpose Test • The benefit under a double tax treaty (either by granting exemption from or deduction of withholding taxes) can be denied to a person, where the principal purpose or one of the principal purposes of any arrangement or transaction, or of any person concerned with such an arrangement or transaction, was to obtain those benefits. • This means that if in a structure there are only tax reasons for putting the structure in place in the first place and there are no business reason to support, then there will be no tax treaty benefit granted and normal taxes will be paid.

MLI, treaty abuse MEASURES TO COUNTER TREATY ABUSE Principle Purpose Test (PPT) “. . a benefit under the Covered Tax Agreement shall not be granted in respect of an item of income or capital if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit” Limitation of Benefits (LOB) a resident of a Contracting Jurisdiction would be entitled to the benefits only if they constitute a “qualified person” under article 7(9) of the simplified LOB

MLI, PE arrangements ARTIFICIAL AVOIDANCE OF PE STATUS AGENCY PE AND COMMISSIONAIRE Source: Change to address “commissionaire arrangements and similar strategies” (art. 12 MLI). Key outcome: Widening of dependent agent PE definition. PREPARATORY OR AUXILIARY EXEMPTION Source: Change to address the artificial avoidance of PE status through the “specific activity exemptions” (art. 13 MLI). Key outcome: Limitation of PE exception for exempt activities. SPLITTING-UP OF CONTRACTS Source: Changes with respect to the artificial splitting up of contracts (art. 14 MLI). Key outcome: Adding of a new anti-fragmentation rule.

MLI, PE arrangements Pre-BEPS, dependent agent PE Commissionaire arrangement R-co % commission fee S-co Not a PE Customer Sale in its own name, but for the account of R-co Pursuant to Art. 5(5) OECD MTC an agency PE is created: Ø If a person is acting on behalf of the enterprise. Ø Concludes contracts in the name of the enterprise. Ø And performs these activities habitually. Pursuant to Art. 5(6) OECD MTC an enterprise shall not be deemed to have a PE if it carries on business Ø through a broker, general commission agent or any other agent of independent status, Ø provided that such persons are acting in the ordinary course of their business.

MLI, PE arrangements (3/5) Pre-BEPS Now PE is created Dependent agent PE where a person acts on behalf of the enterprise and “HAS AND HABITUALLY EXERCISES AN AUTHORITY TO CONCLUDE CONTRACTS ON BEHALF OF THE ENTERPRISE” (i. e. a dependent agent). Dependent agent PE where a person acts on behalf of the enterprise, and, in doing so, such person habitually concludes contracts, OR “HABITUALLY PLAYS THE PRINCIPAL ROLE LEADING TO THE CONCLUSION OF CONTRACTS that are routinely concluded without material modification by the enterprise. ” Construction PE building, construction or installation activities constitute a PE ONLY IF IT LASTS MORE THAN TWELVE MONTHS. Construction PE building, construction or installation activities constitute a PE only if it lasts more than twelve months, provided that complementary ACTIVITIES WHICH WERE PERFORMED BY A COMPANY OR A GROUP OF RELATED COMPANIES SHALL BE CONSIDERED AS ONE UNIT OF ACTIVITIES in the case the activities are connected to each other, i. e. the time periods shall be combined

MLI, PE arrangements (4/5) Pre-BEPS Now PE is not created Auxiliary and supporting activities WHERE A PLACE OF BUSINESS IS USED SOLELY FOR ACTIVITIES LISTED IN THAT PARAGRAPH (article 5(4) of the OECD`s MTC. I. e. use of facilities solely for the purpose of storage, display or delivery of goods or merchandise belonging to the enterprise etc. ). Overall preparatory or auxiliary character where a place of business is used solely for activities listed in that paragraph (article 5(4) of the OECD`s MTC), and THE OVERALL ACTIVITY OF THE FIXED PLACE OF BUSINESS IS OF A PREPARATORY OR AUXILIARY CHARACTER. Independent agent status where a broker, general commission agent or any other agent of an independent status, ACTS ON BEHALF OF THE ENTERPRISE IN THE ORDINARY COURSE OF THEIR BUSINESS, I. E. THEY ACT AS AN ‘INDEPENDENT AGENT’. Independent agent status where a broker, general commission agent or any other agent of an independent status, acts on behalf of the enterprise in the ordinary course of their business, UNLESS THAT PERSON “ACTS EXCLUSIVELY OR ALMOST EXCLUSIVELY ON BEHALF OF ONE OR MORE ENTERPRISES TO WHICH IT IS CLOSELY RELATED”.

MLI, PE arrangements MLI adds a new ANTI-FRAGMENTATION RULE, providing that complementary activities which were performed by a company or a group of related companies shall be considered as one unit of activities in the case the activities are connected to each other, i. e. the time periods shall be combined. Country A Co A Employees of Co A analyse the information given by Office B and take relevant decisions Country B Office B of Co A Employees of Office B perform DD of clients for Co A and send this information to Co A Due to the new anti-fragmentation rule exceptions provided by pre-BEPS MTC would no apply to the Office, because its activities constitute complementary functions that are part of a cohesive business operation.

MLI Provisions Dividends transfer transactions (art. 8 MLI) Gains from alienation of shares in a company, partnership, or trust predominately holding real estate (art. 9 MLI) A 365 day minimum holding period requirement before entities can benefit from exemption “Notwithstanding the provisions of paragraph 2, dividends shall not be taxed in the Contracting State of which the company paying the dividends is a resident if the beneficial owner of the dividends is a company (other than a partnership) that is a resident of the other Contracting State that has held directly shares representing 80 per cent or more of the voting power of the company paying the dividends for a 12 month period ending on the date the dividend is declared” (art. 10 DTT between Australia and Germany) A 365 day minimum ownership period before entities can benefit from exemption “Income, profits or gains derived by a resident of a Contracting State from the alienation of shares or comparable interests may be taxed in the other Contracting State if, at any time during the 365 days preceding the alienation, these shares or comparable interests derived more than 50 per cent of their value directly or indirectly from immovable property, as defined in Article 6, situated in that other State” (art. 13 DTT between Australia and Germany)

MLI, Cyprus experience • • • Entrance into force is expected in January 2021 if the process is completed between October 2019 and September 2020. The question is whethere will be pressure on Cyprus to complete its internal procedures and notify the OECD accordingly. It is understood that discussions are taking place at the OECD level on certain aspects of the MLI. Thus it could reasonably be expected that no pressure would be exerted until the end of this year for the implementation of the MLI by Cyprus chose to apply “minimum standard” of MLI, covering only treaty-abuse provisions and dispute resolution. PPT alone was opted by Cyprus to apply. Matching database

THE EU ANTI-TAX AVOIDANCE DIRECTIVE IMPLEMENTATION IN CYPRUS

THE EU ATAD IMPLEMENTATION IN CYPRUS • Interest limitation: to discourage artificial debt arrangements designed to minimise taxes. • Controlled foreign company (CFC) rule: to deter profit shifting to a low / no tax country. • Exit taxation: to prevent companies from avoiding tax when relocating assets. NOT PART OF THE LEGISLATION. • Switch Over Rule: to prevent companies from non-taxation of dividends received originated from its own profits • Hybrid mismatches: to prevent companies from exploiting national mismatches to avoid taxation. NOT PART OF THE LEGISLATION. • General anti-abuse rule: to counteract aggressive tax planning when other rules don’t apply.

THE EU ANTI-TAX AVOIDANCE DIRECTIVE • The Cypriot Ministry of Finance has presented to the House of Representatives legislation implementing the European Union (EU) Anti-Tax Avoidance Directive (ATAD). The legislation introduces the limitation to interest deductibility, the concept of the Controlled Foreign Company (CFC) and the General Anti-Abuse Rule (GAAR). • The House of Representatives approved the legislation on 5 April 2019 • The provisions of the new law apply to tax years starting 1 January 2019. • The remaining 2 changes for implementing the full requirements of the ATAD, ie introducing the exit taxation regime and the rules countering hybrid mismatches within EU are expected to be introduced and become effective after 2020.

TRANSFER PRICING REQUIREMENTS IN CYPRUS – EXISTING AND NEW LEGISLATION

Transfer pricing requirements in Cyprus • The interpretative Circular refers to the tax treatment of intra group back- to-back financing arrangements • In addition it covers the granting of loans to related parties out of funds borrowed from banks or other third parties • It covers also back-to-back interest free loans • It does not cover loans granted to related parties out of the company’s own funds

Transfer pricing requirements in Cyprus Steps to be taken by taxpayers • Determine if the company has intercompany loans the funds which originate out of borrowed funds • Carry out functional analysis • Determine if it meets the minimum criteria for regulated financial institutions or criteria for simplification procedures • If yes, then no full transfer pricing study necessary • If yes, but want to apply lower margins/returns then the prescribed ones, then full transfer pricing study is necessary • If no, then full transfer pricing study is necessary

Transfer pricing requirements in Cyprus • • • Similar to regulated financial institutions: For intra-group financing companies with functional profile similar to that of a regulated financial undertaking, an after-tax return on equity equal to 10% is considered at arm’s length Simplification measures: The transactions carried out by a Cypriot tax resident group financing company, which pursues a purely intermediary activity (i. e. if grants loans or advances to related companies, which are refinanced by loans or advances obtained from related companies), are deemed to comply with the arm’s length principle, if the company receives in relation to its controlled transactions under analysis, a minimum after tax return 2% on the assets (i. e. 2, 3% on assets) The Company must prove that it acts as a purely intermediary company i. e. performing reduced functions, assets deployed for that purpose are very few and the risks associated with the transactions analysed as low The transfer pricing study should initially include only a functional analysis If the functions do not prove that the assumed risks are reduced then a full economic transfer pricing analysis is required

Transfer pricing requirements in Cyprus • The Transfer pricing analysis should be prepared by a TP expert and must be submitted to the Cypriot Tax Department by a person who has a license to act as an auditor of a company • The Circular applies with effect from 1 July 2017 for all existing and future transactions irrespective of the date of entering into the relevant transactions • Any tax rulings issued on transactions within the scope of this circular, which were issued prior 1 July 2017 will no longer be valid for tax periods after 1 July 2017

Expected Additional Measures in Cyprus on Transfer Pricing • • • Additional guidelines for the application of the transfer pricing rules to the forms of financing activities not covered by the circular Transfer pricing rules and documentation for other forms of intercompany transactions, such as sales, licensing and provision of services The above are expected to be introduced and apply from the year 2020

Expected Additional Measures in Cyprus on Transfer Pricing • Cyprus proposes to introduce legislation to require transfer pricing studies for all transactions between related parties • Related parties are considered those where there is more than 25% shareholding, or the same persons own more than 25% in two or more companies • The OECD Transfer Pricing Guidelines will apply • The Transfer Pricing Documentation will include the Basic File and the Cypriot File • There will be no requirement to maintain a transfer pricing file for companies whose value of transactions with related parties is below EURO 750. 000 per annum • It is expected that the new legislation will apply as from 2020

EXCHANGE OF INFORMATION UPDATE

EXCHANGE OF INFORMATION UPDATE FORMS OF EXCHANGE INFORMATION • Under a double tax treaty between the two countries • Under the Common Reporting Standard • Under the country by country reporting • EU Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation • EU Council Directive (EU) 2018/822 of 25 May 2018, amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (“DAC 6”)

Country by Country reporting (“Cb. C”) • Cb. C reporting requires large multinational enterprises (“MNE”) to file a Cb. C report that will provide a breakdown of the amount of revenue, profits, taxes and other indicators of economic activities for each tax jurisdiction in which the MNE group does business. Cb. C reporting only applies to MNE groups with annual consolidated groups revenue of Euro 750 million or more in the preceding fiscal year (“MNE Groups”)

Country by Country reporting (“Cb. C”) • Cb. C reporting requirements apply in Cyprus for fiscal years beginning on or after 1 January 2016 • The tax authorities of all countries concerned will have for the first time the opportunity to see the whole allocation of profits between the various jurisdictions, the taxes paid in each jurisdiction and the substance available in each location

DAC 6 6 th Directive of Administrative Cooperation • • Additional Measure against aggressive tax planning Imposes Mandatory disclosure requirement when certain arrangements between EU MS or one EU MS and a non-EU MS fall within certain “hallmarks” To become effective as of 01 July 2020 – MS to adopt by 31 December 2019 BUT… Monitoring as of 25 June 2018!

DAC 6 “HALLMARKS” Hallmarks: Generic and Specific broad categories which underline characteristics of potentially aggressive tax planning, some linked with Main Benefit Test : 1. 2. 3. 4. 5. Commercial characteristics seen in marketed tax avoidance schemes Structured arrangements seen in avoidance planning Cross border transactions Arrangements which challenge tax reporting and transparency Transfer pricing arrangements which are not at arm’s length

SUBSTANCE AND TAX RESIDENCY FOR COMPANIES

Structures that are under scrutiny • What was the purpose of these kind of structures? BVI CO INTEREST LOAN CY CO LOAN INTEREST UA CO • No withholding tax for interest payments from UA to CY and from CY to BVI DIVIDEND • No withholding tax on dividends paid from CY to BVI and from BVI to UBOs • No tax paid on dividends received at level of CY co DIVIDEND • Up to 2017 only a 0. 35% margin of interest was taxed in Cyprus • Secrecy of UBOs in the BVI

Structures that are under scrutiny Tax considerations What is the problem of these kind of structures? BVI CO INTEREST LOAN CY CO LOAN INTEREST UA CO • Back to back loan arrangements no longer accepted • Transfer pricing introduced in Cyprus as of 2017 • Beneficial ownership issues – who is the actual owner of the interest and dividends? • Signing of MLI and adaptation of Articles 6 to 11 on treaty abuse • BVI registry of UBOs

Structures that are under scrutiny Other considerations • Tax authorities around the world are getting more sophisticated – Increased transparency – Exchange of information • DAC 6 directive – mandatory disclosure for intermediaries • EU moves to tackle letter box firms' tax avoidance, social dumping – Relocation to other EU countries may be blocked in the case of artificial arrangements to circumvent tax

The new banking reality in Cyprus The NEW Banking reality in Cyprus – Banks in Cyprus closing bank accounts of holding companies with no real substance and transactions in Cyprus – Circular issued by Central Bank of Cyprus in June 2018 – Credit institutions instructed “not to open new bank accounts or continue existing accounts with companies that are regarded as "shell" or "letter box" companies”.

The new banking reality in Cyprus The Central Bank of Cyprus Circular What are ‘shell’ or ‘letter’ box companies? – No physical presence in its country of incorporation apart from a mailing address; – No established economic activity, little to no independent economic value, and no documentary evidence to the contrary; – It is registered in a jurisdiction where companies are not required to file independently audited financial statements; – It has a tax residence in a jurisdiction recognized as a tax haven or no tax residence whatsoever.

SUBSTANCE AND TAX RESIDENCY FOR COMPANIES Substance Requirements • New rules on substance in the new EU Parent/Subsidiary Directive • Rules under EU Commission’s anti-tax avoidance directive are to be implemented as from 2019 • Substance rules under OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan and in particular in treaty shopping and use of tax treaties to be implemented most likely in 2020 • Substance for transfer pricing considerations • Substance in beneficial ownership of income issues • Increased attention by the foreign tax authorities in the exchange of information

SUBSTANCE AND TAX RESIDENCY FOR COMPANIES Substance would determine the company’s tax residency • Statutory substance proves that the company is actually a real company and not a conduit, by paying its taxes filing its tax returns, preparing audited financial statements and meeting all its statutory obligations; • Physical substance is statutory substance, plus an office, telephone facilities, employees, and PROPERLY QUALIFIED directors; • Economic substance refers to more on day to day activities, which is a similar concept to the place of effective management. IT IS A MUST FROM NOW ON THAT ALL THE ABOVE MUST EXIST FOR A COMPANY

SUBSTANCE AND TAX RESIDENCY FOR COMPANIES Physical substance in Cyprus can be achieved by: • Appointing QUALIFIED Directors that are CYPRUS residents, which will be involved in the decision making of the company. Avoid setting up a structure in which the Directors of the Cyprus company are coincidentally the same directors of the source company, or appointing nominee Directors who have only cosmetic duties and are not involved in the Management • Maintaining fully fledged offices in Cyprus • Employing full-time or part-time employees • Relocating senior executives / decision makers to Cyprus • Arid shadow Directors • Carrying out the accounting and HR functions in Cyprus • Maintaining bank accounts with local banks, where income is first received and deposited. At least one of the signatories of the bank accounts should be a Director located in Cyprus • Owning a website that is operated from the employees in Cyprus • Actively participating in the local business community / organizations (ie charities, CIBA, CCCI) • Publicly show ‘’a face ‘’ in the community.

CYPRUS TAX RESIDENCY: BANKING A circular issued by the Central Bank of Cyprus in June 2018 affirms the need to have substance in Cyprus. v Banks are permitted to close bank accounts of holding companies with no real substance or transactions in Cyprus. v Credit institutions have been instructed not to open new bank accounts or to continue to maintain existing accounts with entities that are regarded as “shell” or “letterbox” companies.

SUBSTANCE AND TAX RESIDENCY FOR COMPANIES Definition of tax residency for companies • The majority of the directors’ meetings take place in Cyprus, • The board of directors exercise controls and make the key management and commercial decisions • Board of Directors meetings must ACTUALLY take place • Board of directors minutes are prepared and kept in Cyprus • The minutes must demonstrate the operation of the company is exercised by these RESIDENT directors. • PROPERLY QUALIFIED directors with appropriate knowledge and expertise of the company’s business (i. e. : a doctor as a director in a hospital or a medical company) • Employment relevant to qualified personnel • Having properly equipped offices relevant to the size and operation of the company.

Why Cyprus? A brief look at the Cyprus Tax System • Low corporate tax of 12. 5% • No withholding tax on dividends paid to non-tax resident individuals • 50% tax exemption for new tax residents who earn more than € 100. 000 per year • Cyprus tax residents who are not domiciled in Cyprus are exempt from special defense contribution • Profits on the disposal and revaluation of shares is not taxable • Full compliance with EU and OECD • Beneficial IP Regime • Dividend income exempt from taxation (under certain conditions) • Capital gains tax only on property situated in Cyprus • Foreign exchange gains are not taxable (not applicable for Forex)

WHAT YOU NEED TO DO More observations • EU Directive on intermediaries • Review: IP, B 2 B loans, Holding structures • Apply PPT in your structure • Convert B 2 B to NID instead • Beneficial Ownership issues • Does your structure have a CFC? • Substance. Revisit urgently. • Trends: Caribbean moving to Cyprus and Bulgaria • Substance in Lux /Netherlands = Onerous & highcost. Companies moving to Cyprus (MHP Myronivsky Hliboproduct example) • Where is your company actually resident? ? • Substance will Re- Open your bank account !!!!

Demonstrating Substance

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