course content
19/06/2025: 09:00 a.m. - 12:30 a.m.
Module 1: Taxation of Intercompany Dividends – Part A
1.1. Cyprus domestic rules on dividend income
General exemption from income tax and SDC implications.
1.2. Participation exemption
Conditions for SDC exemption on dividend income (holding period, passive income, subject-to-tax test).
1.3. Deemed dividend distribution (DDD)
Provisions applicable to undistributed profits of Cyprus-resident companies.
1.4. Anti-abuse measures
GAAR and “non-genuine arrangement” considerations under domestic law.
1.5. Outbound dividends
Absence of withholding tax on payments to non-residents.
1.6. Inbound dividends
Treatment of dividends from EU and non-EU jurisdictions; SDC implications depending on effective taxation and substance.
Module 2: Taxation of Intercompany Dividends – Part B
2.1. EU Parent-Subsidiary Directive
Requirements for exemption, including 10% participation and holding period.
2.2. Anti-abuse rules under the Directive
Denial of benefits due to artificial arrangements or principal purpose test.
2.3. Interaction of EU law with Cyprus domestic law
Harmonisation and relevant ECJ case law (e.g. Danish Beneficial Ownership Cases).
2.4. Tax treaties
Application of Article 10 of the OECD Model Convention, treaty WHT rates, and access conditions.
2.5. Beneficial ownership
Interpretation under treaties and EU law, and its impact on Cyprus holding structures.
2.6. Case studies
Common inbound and outbound dividend structures through Cyprus, risk assessment, and documentation best practices.
Tax advisors and accountants
Corporate and commercial lawyers
Finance directors and CFOs
Compliance officers
Corporate service providers and administrators
In-house legal and tax professionals in multinational groups
