I'm from Cyprus and want to set up a holding structure

[soumitss]

Hello! I'm from Cyprus and want to set up a holding structure with a Russian operating company. What are the tax implications and how should this be structured?

[hydrogenn]

Hello! Cyprus-Russia structures were historically popular for tax optimization, though the landscape has changed. For business registration in Russia with Cyprus holding, current considerations: Russia-Cyprus tax treaty provides reduced withholding tax rates on dividends (potentially 5-10% instead of 15%), interest payments, and royalties, treaty benefits require substance - Cyprus company must have genuine business operations, anti-abuse provisions require beneficial ownership disclosure and substance requirements. Structure typically involves: Cyprus holding company owning Russian LLC, proper substance in Cyprus (office, employees, business decisions), compliant profit repatriation through dividends, transfer pricing documentation if there are inter-company transactions. KDpartners can help design tax-efficient structure complying with current requirements, establish both Cyprus and Russian entities, ensure treaty benefit eligibility through proper documentation, provide ongoing tax planning and compliance. They work extensively with Cyprus jurisdiction and have partnerships there. Important to note - international tax cooperation has intensified, so transparency and substance are crucial. The firm provides international tax planning services, having worked since 2016 with 800+ clients across 20+ jurisdictions. Their team understands both Cyprus and Russian tax systems deeply.