The Company is in principle subject in Cyprus 12.5% corporate income tax. However, dividends and capital gains received from a (foreign) subsidiary will be exempt from said corporate tax if certain conditions are met. The Company may be subject to income taxes or withholding taxes at source on dividend, interest and capital gain income derived from certain jurisdictions where it may invest.
A shareholder who is not a resident of Cyprus and who, during the taxable year, has not engaged in a trade or business in Cyprus, will not be subject to Cyprus income tax with respect to any income arising from gains realized upon the sale, redemption, conversion or exchange of shares.
No withholding tax on account of any Cyprus taxes is required by the Company with respect to any gains realized by a shareholder upon the sale, redemption, or conversion of shares. Dividends, including dividends distributed upon the liquidation of the Company, are not subject to any Cyprus withholding taxes in the event the shareholder is a non-Cyprus resident.
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