INTRODUCTION
Cyprus is not only an attractive business location for holding, financing and other passive investment activities. Thanks to a wealth of fiscal and other advantages, Cyprus also forms a very appealing proposition for establishing companies with commercial activities.
If substance is implemented by international business companies it can lead to very important benefits, including the minimization of chances for disputes concerning their role by foreign tax, and other authorities. Considering the ever intensifying initiatives around the world against superfluous establishments, such as the so called de-offshorisation in Russia and the Base Erosion…
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