How to establish Cyprus company for Norwegian trading company?

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nastathin

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Feb 18, 2011
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Hi,


I have a Norwegian trading company which has been active for 7 years I want to sell it to a Cyprus holding company before I take out dividends in about 3 months.


Can someone help how to go around it?
 
This transaction can indeed be difficult since you will face complications with your local tax authorities, even if you sell the Norwegian company for let's say €1 then the Tax auth. will estimate what the company really is worse based on turnover and goodwill. It may be different in Norway so I would suggest you address this question to a local tax advisor (one of the big brands) they will properly know what to do.


Alternative, you can invoice your Norwegian company from the Cyprus Holding (Trading) company, but you will fall under the Transfer Pricing regulations which are very complicated. That said, then it all depends on how much money we speak and the size of the Norwegian company.


Depending on some of the answers that may be the outcome of the above it would also be possible to make some more sophisticated setup which in certain cases can help to prove that the two companies (Cyprus & Norwegian) are not related to each others nor the ownership so to avoid any Transfer Pricing regulations.


I would recommend you to get in touch with a local tax advisor or even tax lawyer to help you, also you can submit a ticket to us and we may look into it.


For the future and to other new businesses, then it is always good to plan your company setup before you start trading, it is always more complicated (if at all possible) and more expansive to do changes to the company structure later as it is the case above! The problem we realize is that most often a startup / new business don't have the money in the beginning or simply not want to spend that much before it seems the company is running stable.

Last edited: May 30, 2016
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Disclaimer: Nothing I say should be taken as tax, legal or financial advice. Anything I say is for general informational purposes only. Always seek independent professional advice.
 
So it can't be done aftwerwards but would have needed to be in place before the Norwegian company was started up correct?
 
woogold said:
woogold said:
So it can't be done aftwerwards but would have needed to be in place before the Norwegian company was started up correct?
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Yes it would have been recommended to have had the Offshore / Cyprus holding company in place first.

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Thanks to my tax & legal advisor I managed this transaction with only little tax to be paid! I'm glad I incorporated in Cyprus after all.
 
jfk said:
jfk said:
Thanks to my tax & legal advisor I managed this transaction with only little tax to be paid! I'm glad I incorporated in Cyprus after all.
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What tax did you pay? I mean the amount in EURO you paid to make this transaction?
 
JFK, are you able to answer this question?

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Only the early bird catches the worm.
 
I assume the question is a very high privacy level so he won't like to answer at all 😉

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Since I am new in this forum, I don't have any idea on that matter since it was a little bit of confidential. Why would not ask for a friend who knows about this kind of business.
 
joshuabelanger said:
joshuabelanger said:
Since I am new in this forum, I don't have any idea on that matter since it was a little bit of confidential. Why would not ask for a friend who knows about this kind of business.
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Please elaborate on this answer, I don't get it? 🙂

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