CYPRUS COMPANY: VAT ON HOLDING ACTIVITIES
It’s been too long since we last looked at this topic and frankly, given the importance of the VAT treatment of holding activities in Cyprus, we can’t wait to bring this topic back to the seminar room!
The Chelco VAT International Academy continues its series of high-level VAT educational events with a morning seminar focussing on the VAT treatment of holding activities, including the buying, issuing, holding and sale of shares.
A Cyprus-established holding company is the cornerstone of international business on the island. Yet the legislation is not particularly helpful given there are but a mere few sentences available. What has been much more helpful is the guidance provided over the years from the European Court of Justice (ECJ).
- When is a holding company a taxable person and when is it not?
- When is it obliged to apply the reverse charge mechanism, including the domestic reverse charge on construction services or purchasing of certain IT equipment?
- What are the implications with regards to VAT deductions when such activities involve holding, buying, issuing or selling shares?
- What guidance exists from the Department of Taxation?
These and many other VAT related issues will be addressed and discussed at the seminar, with reference to key judgments of the ECJ spanning decades of case law. This will be a seminar with direct impact on the everyday practice followed by professionals dealing with the VAT matters of holding activities, and will help build up and enhance current knowledge.
The seminar will focus on:
- Discussion of when a holding entity can be considered a ‘taxable person’ for VAT purposes;
- Discussion and interpretation of the term ‘direct or indirect involvement in the management of the companies in which the holding has been acquired’;
- Discussion and interpretation of the term ‘economic activity’ and ‘non-economic activity’;
- Discussion and interpretation of when an activity ‘constitutes the direct, permanent and necessary extension of its business’;
- Discussion of how the status of a holding company impacts its right to deduct input VAT;
- Discussion of when a holding company should apply the ‘reverse charge’ mechanism on services received from Cypriot suppliers and international suppliers;
- Discussion of implications for holding companies as members of a VAT group;
- Analysis of a plethora of ECJ decisions related to holding entities.
The seminar is open to any professional with exposure to VAT matters such as accountants, chief accountants, CFOs, financial controllers, tax lawyers, tax advisors, et al.
DOWNLOAD THE SEMINAR BROCHURE IN ENGLISH
Registration & Coffee
Alexis Tsielepis: Instructor
- The legislation
- Treatment of dividends
- The importance of consideration
- The case of Polysar: When is a holding entity considered a ‘taxable person’ for VAT purposes
- Holding of shares vs holding of bonds
- How a holding entity should apply the ‘reverse charge’ mechanism
- Understanding the term ‘direct or indirect involvement in the management’
- Interpretive Circulars 222 & 225
Short Coffee Break
- Deductions – general principles
- Deductions and the issue of shares
- Deductions and the purchase of shares
- Deductions and the sale of shares
- Holding companies and VAT Groupings
Questions and Discussion
End of Seminar
Alexis is widely considered as the foremost expert on VAT in Cyprus. With more than 15 years of experience in VAT strategic consulting, he advises businesses on local and international VAT matters and lectures at local and international VAT conferences.
Alexis possesses an extensive vocational and educational experience in European VAT and a detailed comprehension of EU VAT matters and decisions of the European Court of Justice (ECJ). He has served on various committees charged with tax matters and his work includes liaising with the Cyprus tax authorities and government on policymaking.
He has written a number of tax syllabuses, chapters and articles on matters pertaining to Cyprus and EU VAT. He is the author of the book “An in-depth analysis of the Fixed Establishment concept and a comparison with the Permanent Establishment concept”.
Alexis is a Fellow of the Institute of Chartered Accountants in England and Wales (ICAEW), and holds the Expert in European Value Added Tax Degree, which he earned with the highest grade ever awarded in the history of the coveted diploma. He is a Partner and a Director of the VAT Forum in Belgium and the co-founder and Vice-Chairman of the Cyprus VAT Association (CYVA).
He is also a Certified Vocational Trainer with the Human Resources Development Authority of Cyprus (ANAD).
Alexis is sharing his knowledge on VAT, in a series of seminars and workshops organised by the Chelco VAT International Academy, covering an array of VAT-dedicated topics, with the crown jewel being the recently launched Diploma in VAT Excellence (DiVE), a 10-month course covering EU and Cyprus VAT law in a depth never before seen in Cyprus.
Who Should Attend?
When, Where & How Much?
Friday, 31 March 2023, Columbia Plaza Venue Centre
9:00am – 1:30pm (Registration at 8.30am)
4 CPD Units (certificates of attendance will be provided)
€175 + VAT
Group Discount (for 3 persons or more): 15%
Free for current students of the Diploma in VAT Excellence (DiVE).
Mention in Notes when registering.