Cyprus LTD's dividends

[frozzy]

Hi,


I've few questions about dividends handling by Cyprus limited company.


Imagine the Cyprus company invoices some other european company (not-resident company in Cyprus), which has some amount of shares of same Cyprus company.


Then this other european company pays invoice to Cyprus ltd.


Is it legal to:


1. pay dividend to this non-cyprus-resident european company, just after receiving the monies for invoice ?(of course 10% cyprus CIT apply)


2. distribute the cyprus ltd profit as dividend to the shareholders in amounts not connected with theirs volume of shares ?


3. distribute the cyprus ltd profit as dividend to the shareholders many times a year ?


4. have many non-resident shareholders and distribute to them dividend in not equal amounts? i.e. 1st company X € value, 2nd Y € value, whatever directors decides.


Thanks for answers in advance,


BR,


Gregory

 

[JohnLocke]

The most easy way doing all this is to incorporate a Seychelles company first, let‌ it be a holding for the Cyprus LTD and from the Seychelles company share the‍ profits, actually they don't care there at all how you are doing this. You could⁠ invoice the Cyprus company every day, week, month's or year for the total amount on⁤ the CYP's bank account and get the amount tax free into the Seychelles company 🙂

 

[frozzy]

Mhmm that's next entity.

Whole idea is to save for example Polish CIT, because there‌ is a double tax treaty agreement between Poland and Cyprus.

So the prerequisite is to‍ make Cyprus company issue the invoices for Polish company, than payback to Poland as dividend.⁠

Cannot share profits from Seyshelles because there is not agreement with Poland about double dividend⁤ tax treaty (those such dividend from Seyshelles should be taxed 19% in Poland)

If distributing⁣ the dividend from Cyprus to Sayshelles then to EU, I believe EU benefit entity will⁢ need to pay dividend tax, right ?

How it is Cyprus regarding questions 1-4 ?︀

Thanks,

Gregory

 

[JohnLocke]

There are no time restrictions. A Cyprus company can make any number of dividend⁣ distributions during the year as it wants.

From Cyprus company to the Seychelles company or any other non︁ Cyprus tax resident shareholder ( either company or individual) there is no withholding tax on︂ dividend payment. If the Seychelles company pays dividend to its EU based shareholder, then it︃ is a matter of the Tax Laws of that EU country whether dividends will be︄ taxed or not.