The provision of advice in taxation matters, including international tax planning, is a key component of our practice, and it plays a key role in various transactions such as finance transactions, mergers and acquisitions, cross-border operations, as well as company establishment and group structuring and restructuring.

Recognizing the significance of providing comprehensive and efficient tax advice, the Firm’s legal team continually strives to assess the current developments and international trends in relation to tax transparency, substance and value creation, and at the same time to optimally utilize the Cyprus double taxation treaty network and the existing tax advantages and benefits offered by the tax systems of various jurisdictions to obtain the most effective tax planning opportunities for its clients.

Patrikios Pavlou & Associates LLC has extensive expertise in advising and assisting clients in attaining tax efficiency in international cross-border transactions and meet their financial and business objectives.

 

The Firm’s tax advisory services include:

Through the identification of efficient tax structuring routes and optimizing cross-border group structures, clients can achieve their business objectives. The professionals of our firm can advise not only on proposed but also on existing tax structures to optimise their efficiency. Also, our tax team provides advice on the tax aspects and consequences of any transaction.

Through the incorporation, maintenance and administration of companies and other legal entities in Cyprus or on the international level.

Assisting for the implementation of any proposed local or cross border structure. Incorporation and maintenance of companies and other legal entities in Cyprus or abroad. Provision of secretarial and administration services. Our firm is a one-stop shop offering all services related with the establishment, corporate and accounting administration, as well as liquidation and dissolution of companies.

Implementing restructurings and reorganizations, including local and cross-border mergers and advising on obtaining all tax benefits provided by the relevant legislation.

Advising in relation to the creation of substance in line with the current trends on the local and the international level including the BEPS action plans and the nexus approach, the setting up of fully-fledged offices and meeting the requirements of the local regulations, aligned with any applicable double tax treaties.

Provision of advice on any VAT, tax and accounting matter, including assistance with obtaining tax rulings. The provided tax advice and assistance can cover a wide range of areas including income tax considerations, special defence contribution, obtaining tax residency and the non-domiciled status as well as obtaining the benefits, exemptions and deductions offered by the Cyprus tax legislation.

Provision of advice in relation to the transfer pricing requirements including assistance for obtaining any necessary transfer pricing study.

Provision of legal advice and legal representation in relation to any matter within our practice areas

Patrikios Pavlou & Associates LLC has an established reputation as one of the leading law firms in the field of tax planning, but above all it is an internationally renowned legal practice that aims at meeting any expectations of both institutional and private equity clients.

The Firm offers continuous advice from the Cyprus law perspective on various tax matters to a number of large international law firms but also to high net worth individual clients. To ensure the utmost satisfaction of clients, the Firm additionally maintains professional corporate and accounting/bookkeeping departments, and close associations with expert audit firms thereby allowing their clients to receive the full spectrum of services in accordance with their individual needs.

Furthermore, through the association with Pagecorp Group, the Firm provides comprehensive corporate and accounting services, such as the incorporation and maintenance of legal entities, company secretarial services, the setting up and administration of Cyprus international trusts, re-domiciliation of companies in or out of Cyprus, accounting and financial reporting, VAT and VIES registration and administration, payroll processing and administration, to a variety of clients in Cyprus and overseas.

Patrikios Pavlou & Associates LLC was selected to become the sole member for Cyprus of ‘AITC’ – Association of International Tax Consultants, an Internet-based network of independent corporate and tax professionals located in financially important centers around the world. Membership of AITC is by invitation only to firms that have the highest standards of professional competence and integrity.  Through their association with AITC, Patrikios Pavlou & Associates LLC provides swift and accurate advice to clients regarding aspects of their local and international business arrangements, aimed at minimizing taxes through carefully controlled management of corporate and personal structures.

Sample of Major Cases Handled

  • Advising a Russian airline company in relation to the tax consequences arising out of a financing scheme concerning the leasing of Boeing and Airbus aircrafts, involving UAE, Cypriot and Irish entities. We provided specialised tax advice in relation to transfer pricing and VAT matters and other relevant taxes.
  • Provided legal advise to an international tax and corporate services provider, in relation to a proposed restructuring of a tax structure involving Cyprus, Russian, BVI, New Zealand and Swiss entities and on the tax consequences of the restructuring. Advised on the settlement of a new trust in New Zealand and of the proposed irrevocable contribution in kind of shares in a Russian company, to a Cyprus company subsidiary of such new trust.
  • Provided an expert legal opinion in connection with legal proceedings taking place in the Russian Federation involving a Cyprus holding company, analysing the concept of the beneficial ownership of dividends under the OECD model treaty and the double tax treaty between Russia and Cyprus, the concept of a conduit company and the effective management and control of the Cyprus company involved.
  • Advised one of the major banking institutions of Cyprus in relation to whether a general issuing bank agreement entered into by the Cypriot Bank and an international developmental investment bank is subject to stamp duty in Cyprus.
  • Advised a Russian entrepreneur, provider of online travel and holiday services accommodating a niche market of travelers seeking to enjoy alternative experiences ranging from hunting and fishing to trekking and ecotourism, on all legal matters relating to the setup of a specialist online based tourism company and website. Our client’s Cyprus based company seeks to benefit from the beneficial IP Box tax regulations in Cyprus that provide a tax efficient platform for the development of IP-related assets and enterprises.
  • Seeking to benefit from the Double Taxation Treaties in place between Cyprus and several other countries, including Russia, we advised a number of Companies from the BVI and Panama wishing to transfer their base for tax purposes. Provided our legal opinions on tax matters relating to re-domiciliation to and from Cyprus to our multijurisdictional clientele.
  • Advised a Greek based data security company in relation to the establishment of a Cyprus subsidiary for the purposes of facilitating international sales of its software products.
  • Advised various foreign individuals in obtaining the Cyprus Citizenship through the Cyprus citizenship by investment programme, in relation to the requirements for becoming tax residents of Cyprus and acquiring the non-domiciled status.
  • Advising a high-net-worth individual owner of an interactive online marketing agency and other online platforms, in relation to the settlement of a Cyprus International Trust (CIT) for the purposes of utilizing the same as a wealth management and estate planning tool. We advised on the setting up and registration of the CIT and all related tax implications.
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