Since 2008, WIN has been partnering with Waylus Management Ltd who provides managerial and operational counsel and assistance to Cypriot and foreign companies. We are well positioned to advise and assist companies in need of proof of economic substance, whether established in Cyprus or in the process of establishing themselves or relocating there.

Why the Urgency?

In 2012, the G20 introduced the BEPS (Base Erosion and Profit Shifting) plan to counteract tax planning, which was perceived as a major economic threat, especially where “profits are geographically divorced from activities”. Companies will be required to provide proof of effective management in the countries they operate, which in turn is considered as proof of residence in such countries, and also disclaim real beneficial ownership of the company to ensure that the income received by the company is actually going to the company itself and not to another entity.

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Lack of economic substance is nowadays perceived as tentative tax avoidance by most tax authorities in the world, and tax optimization schemes are scrutinized for possible tax abuse or tax evasion. Tax authorities worldwide are encouraging international cooperation to fight tax avoidance and to ensure companies have real commercial value. Investigations by foreign tax authorities about Cypriot-based companies are now significantly higher, and mainly include the request for information about the proper exercise of control from the foreign jurisdiction and the relevance of having foreign residents appointed in the management and directorship of the company. “Nominee” directors will be challenged for their qualifications and independence. Their presence in Cyprus and the actual decision-making process will be scrutinized to ensure compliance with the law stating that “a company is tax resident of Cyprus if its management and control is exercised within the Republic of Cyprus”.

Waylus Management Ltd can provide ready-made packages for substance solutions, however we do not encourage such an approach, as every business has its own specific requirements and structure. We shall in every case review the business specifics, environment, and realizable returns before proposing the most appropriate solution, ensuring that all legal and tax requirements are met and therefore avoiding any future challenge or mishap.

As your local Partner we will be providing the following services:

1. Assessment of substance requirements
2. Company incorporation
3. Management & administration services
4. Business Development services including sales, marketing and branding
5. Provision or recruitment of staff
6. Accounting and audit
7. Insurance policy coverage
8. Office rental including full set up of communications and technology….

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