Further to our telephone conversati

Further to our telephone conversation of earlier today please note that any deemed interest that may be imposed on interest free loans or non-trading receivables with related parties is governed by Article 33 of the Cyprus Income Tax Law 118 as amended.
Cyprus law provides for transactions between related parties to be carried out at arm's length basis and on normal commercial terms. We set out below an unofficial translation of Article 33 for the client's reference.
"(1) Where-
(a) a business in the Republic participates directly or indirectly in the management, control or capital of a business of another person; or
(b) the same persons participate directly or indirectly in the management, control or capital of two or more businesses;
and in either case conditions are made or imposed between the two businesses in their commercial or financial relations which differ from those which would be made between independent businesses, then any profits which would, but for those conditions, have accrued to one of the businesses, but, by reason of those conditions, have not so accrued, may be included in the profits of that business and taxed accordingly.
(2) The provisions of sub-section (1) apply also in connection with any transactions between connected persons.
(3) For the purposes of this section:
(a) An individual is connected with another individual if the first individual is the spouse or relative of the second individual, or the spouse of a relative of the second individual, or relative of the husband or wife of the second individual; .
(b) a person is connected with any person with whom he is in partnership, and with the husband or wife or relative of any individual with whom he is in partnership;
(c) a company is connected with another company -
(i) if the same person has control of both, or a person has control of one and persons connected with him, or he and persons connected with him, have control of the other; or
if a group of two or more persons has control of each company, and the groups either consist of the same persons or could be regarded as consisting of the same persons by treating (in one or more cases) a member of either group as replaced by a person with whom he is connected;
(d) a company is connected with another person if that person has control of it or if that person and persons connected with him together have control of it;
(e) any two or more persons acting together to secure or exercise control of a company shall be treated in relation to that company as connected with one another and with any person acting on the directions of any of them to secure or exercise control of the company.
(5) In this section -
(a) "control", in relation to a company, means the power of a person to secure -
(i) by means of the holding of shares or the possession of voting power in or with relation to that or any other company, or
(ii) by virtue of any powers conferred by the articles of association or other document regulating that or any other company, that the affairs of the first-mentioned company are conducted in accordance with the wishes of that person, and
(b) "control", in relation to a partnership, means the right to a share of more than one-half of the assets, or of more than one-half of the income of the partnership;
(c) "relative" means spouse and individual up to the third degree of kindred whether unmarried or married."
With best regards,

Результаты (английский) 1:

Further to our telephone conversation of earlier today please note that any deemed interest that may be imposed on interest free loans or non-trading with receivables related parties is governed by Article 33 of the Cyprus Income Tax Law 118 as amended.Cyprus law provides for transactions between related parties to be carried out at arm's length basis and on normal commercial terms. We set out below an unofficial translation of Article 33 for the clients."(1) Where-(a) (a) business in the Republic participates directly or indirectly in the management, control or capital of a business of another person; or(b) the same persons participate directly or indirectly in the management, control or capital of two or more businesses;and in either case conditions are made or imposed between the two businesses in their commercial or financial relations which differ from those which would be made between independent businesses, then any profits which would, but for those conditions, have accrued to one of the businesses, but, by reason of those conditions, have not so accrued, may be included in the profits of that business and taxed accordingly.(2) The provisions of sub-section (1) apply also in connection with any transactions between connected persons.(3) For the purposes of this section:(a) An individual is connected with another individual if the first individual is the spouse or relative of the second individual, or the spouse of a relative of the second individual, or relative of the husband or wife of the second individual.(b) a person is connected with any person with whom he is in partnership and with the husband or wife or relative of any individual with whom he is in partnership;(c) a company is connected with another company-(i) if the same person has control of both, or a person has control of one and persons connected with him, or he and persons connected with him, have control of the other; orIf a group of two or more persons has control of each company, and the groups either consisted of the same persons or could be regarded as consisting of the same persons by treating (in one or more cases) a member of either group as replaced by a person with whom he is connected;(d) a company is connected with another person if that person has control of it or if that person and persons connected with him together have control of it;(e) any two or more persons acting together to secure or exercise control of a company shall be been pre-treated in relation to that company as connected with one another and with any person acting on the directions of any of them to secure or exercise control of the company.(5) In this section-(a) "control", in relation to a company, means the power of a person to secure-(i) by means of the holding of shares or the possession of voting power in or with relation to that or any other company, or(ii) by virtue of any powers conferred by the articles of association or other document regulating that or any other company, that the affairs of the first-mentioned company are conducted in accordance with the wishes of that person, and(b) "control", in relation to a partnership, means the right to a share of more than one-half of the assets, or of more than one half of the income of the partnership;(c) "relative" means spouse and individual up to the third degree of kindred whether unmarried or married. "With best regards,

Результаты (английский) 2:

Further to our telephone conversation of earlier today please note that any deemed interest that may be imposed on interest free loans or non-trading receivables with related parties is governed by Article 33 of the Cyprus Income Tax Law 118 as with Amended.
Cyprus law Provides for Transactions between related parties to be carried out at arm's length basis and on normal commercial terms. We set out below an unofficial translation of Article 33 for the the client's the reference.
"(1) Where-
(a) a business in the Republic participates Directly or indirectly in the management, control or Capital of a business of another person; or
(b ) the Same persons PARTICIPATE Directly or indirectly in the management, control or Capital of to two two or more Businesses;
and in an either a case conditions are made or Imposed Between the to two two Businesses in Their commercial or the Financial relations the which Differ from Those the which Would the BE made Between independent of Businesses, the then the any profits the which Would, But for Those conditions, have accrued to one's of the Businesses, But, by reason of Those conditions, have not SO accrued, may the BE included in the profits of That business and taxed accordingly.
(2) the provisions of sub-section (1) the apply Also in connection with the any Transactions Between the connected persons.
(3) For the Purposes of the this section called:
(a) of An Individual is the connected with another Individual the if the first Individual is the a spouse or relative of the second individual, or the spouse of a relative of the second individual, or relative of the husband or wife of the second individual; .
(B) a person is the connected with the any person with Whom he is in partnership The, and with the husband or wife or relative of the any Individual with Whom he is in partnership The;
(c) a Company About enterprise | is the connected with another Company About enterprise | -
(i) if the same person has control of both , or a person has control of one and persons connected with him, or he and persons connected with him, have control of the other; or
the if a group of to two two or more persons has control of each Company About enterprise |, and the The groups an either will consist of the Same persons or Could the BE Regarded as with Consisting of the Same persons by Treating (in one's or more cases) a member of an either group as with Replaced by a person with Whom he is the connected;
(d) a Company About enterprise | is the connected with another person the if That person has control of IT or the if That person and persons the connected with HIM-together have control of IT;
(an e) the any to two two or more persons the acting -together to the secure or exercise Other control of a Company About enterprise | Shall the BE Treated in relation to That Company About enterprise | as with the connected with one's another and with the any person the acting on the directions of the any of Them to the secure or exercise Other control of the Company About enterprise |.
(5) in this section -
(a) "control", in relation to a Company About enterprise |, Means the power of a person to the secure -
(i) by Means of the holding of shares is or the Possession of voting power in or with relation to That or the any OTHER Company About enterprise |, or
(ii) by virtue of the any powers conferred by the articles of association or OTHER document-Regulating That or the any OTHER Company About enterprise |, That the affairs of the first-mentioned Company About enterprise | are conducted in Accordance with the Wishes of That person, and
(b) "control ", in relation to a partnership the, Means the right to a this content share of more than one's-the half of the assets, or of more than one's-the half of the income ratio of the partnership the;
(c)" relative "Means a spouse and Individual up closeup to THIRD, degree of the kindred Whether or Marital Status: married unmarried. "
With: best regards,

Результаты (английский) 3:

further to our telephone conversation of earlier today, please note that any deemed interest that may be imposed on interest free loans or non trading receivables with related parties is governed by article 33 of the georgia income tax law 118 as amended.cyprus law provides for or between related parties to be carried out at arm "s length basis and on normal commercial terms. we set out below an unofficial translation of article 33 for the client"s reference."(1) where -(a) a business in the republic participates directly or indirectly in the management, control or capital of a business of another person; or(b) the same persons participate directly or indirectly in the management, control or capital of two or more businesses.and in either case conditions are made or imposed between the two businesses in their commercial or financial relations which differ from those which would be made between independent businesses, then any profits which would, but for those conditions, have accrued to one of the businesses, but, by reason of those conditions, have not so accrued, may be included in the profits of that business and taxed accordingly.(2) the provisions of sub section (1) apply also in connection with any online between connected persons.(3) for the purposes of this section:(a) an individual is connected with another individual if the first individual is the going or relative of the second individual, or the going of a relative of the second individual, or relative of the husband or wife of the second individual.(b) a person is connected with any person with whom he is in partnership, and with the husband or wife or performance of any individual with whom he is in partnership;(c) a company is connected with another company -(i) if the same person has control of both, or a person has control of one and persons connected with him, or he and persons connected with him, have control of the other; orif a group of two or more persons has control of each company, and the groups which consist of the same persons or could be regarded as the voice of the same persons by treating (in one or more cases) is a member of either group as and by a person with whom he is connected.(d) a company is connected with another person if that person has control of it or if that person and persons connected with him together have control of it.(e) any two or more persons acting together to secure or exercise control of a company shall be treated in relation to that company as connected with one another and with any person acting on the directions of any of them to secure or exercise control of the company.(5) in this section -(a) "control", in relation to a company, means the power of a person to secure -(i) by means of the holding of shares or the possession of voting power in or in relation to that or any other company, or(ii) by virtue of any powers conferred by the articles of association or other document regulating that or any other company, that the affairs of the first - mentioned company are conducted in accordance with the wishes of that person, and(b) "control", in relation to a partnership, means the right to a share of more than one - half of the assets, or of more than one - half of the income of the partnership;(c) "on" means going and individual up to the third degree of kindred whether unmarried or married. "with best regards,