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Immovable property outside Cyprus
Dealing in immovable property in other treaty countries constitutes
business profits as far as the absence of a permanent establishment can be shown
by the Cyprus IBC. The absence of the permanent establishment can be
achieved by the use of an independent agent. This is frequently used in
the case of immovable property in the United Kingdom.
An immovable property is held by an IBC for two reasons:-
For trading The double tax treaties of Cyprus provide
that no income tax or capital gains tax is payable in that other country (USA
and Canada excluded).
If the profit received in Cyprus is deemed as income is taxed at the rate of
10% and if is deemed of a capital nature the tax is nil.
For investment The sale of shares in the IBC holding the
immovable property may in some cases result to extraction of gains without the
payment of tax (especially in the case of United Kingdom).
Immovable property in Cyprus IBC’S IBC’S in Cyprus
are not allowed to hold immovable property in Cyprus other than their own
offices and premises for the residence of their foreign employees provided they
maintain a fully fledged office. Any gain on disposal of such premises is
taxed at the capital gains tax rate of 20%.
Individuals On disposal of the property, there will be
capital gains tax at the rate of 20% on the gain. The first C£10.000 (or
C£50.000 in the case of one’s private residence) is exempt.
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