Cyprus IP Company: The Breathless Conundrum Solved

The breathless conundrum for IP companies is four-fold: not only should royalties be taxed at a low rate in order to maximise profits; but also research and development (R&D) or acquisition costs should be considered as allowable expenses to the maximum possible effect, whilst also the jurisdiction where the IP holding is situated should have a considerable treaty network in order to allow for global exploitation of the IP rights, not forgetting that an […]

By |February 26th, 2015|

India: Flagging Off Some Tax Issues On Sale Of Digital Capacity

Income from sale of digital capacity treated as business income
However, Tribunal warns that the characterization is case specific and would depend on whether the transferee exercises the rights of an owner or a licensee
In this case, the transferee was considered to be an owner as it had the right to lease or on sell the digital capacity, and ability to participate in management decisions
Limited clarity provided on situs of digital capacity

In a judgment that […]

By |February 25th, 2015|

Definition Of The Russian Tax Residency For Individuals – Potential Changes?

The Russian Federal Tax Service (“FTS”) has prepared a letter clarifying criteria for determining the Russian tax residency for individuals (the “Letter”).

Currently the Russian Tax Code views an individual as a Russian tax resident if they are physically present in Russia for 183 days in any 12 month consecutive period. This definition is exhaustive and does not refer to any other sources, or allows for any substantial interpretation.

The letter of the FTS refers to the provisions […]

By |February 25th, 2015|