Training Objectives

Specifically this program focuses upon; 

• The program aims to familiarize learners with major latest provisions of Cyprus tax laws and related judicial pronouncements pertaining to corporate taxation governance. 
• This program will enable the learners to cover matters concerning the provision of taxpayers’ rights in Cyprus that are currently promoted within Cyprus domestic law, as well as taxpayers’ rights that are promoted through the Taxpayers’ Charter.  
• This program deals with the fight by the EU and the OECD against Base Erosion and Profit Shifting (BEPS). The chapter demonstrates briefly techniques which are commonly used by MNEs in BEPS. Likewise, the for this program most relevant action plans of the OECD and some decisions made on these actions plans are analysed. The same is done for the EU. The main focus in this chapter is on the protection of taxpayers’ rights with respect to measures taken against BEPS.  
• About the relationship between taxpayers’ rights and human rights it is suggested that, taxpayers’ rights are a derivative of human rights. Most of the human rights that are promoted in domestic law and international treaties are also accessible to taxpayers.   
• The introduction of separate treaties or conventions only for taxpayers’ rights will to a certain degree increase certainty as to the rights a taxpayer is entitled to enjoy. Probably it will also reduce taxpayers’ resources being spent to confirm whether or not a certain right is intended for tax matters

Training Outline

The Cyprus tax system  

•  Introduction  
• History of the Cyprus tax system  
•  Power to tax  

Corporate Tax  

• Taxable subject 
•  Taxable object (general remarks)  
•  Income from business activities  
• Income from investment  
•  Corporate tax rates  
• Taxation of associated companies  
• Inter-company pricing  
•  Taxation of group companies  
• Taxation of repatriated income of a Cyprus permanent establishment 
•  Taxation of a controlled foreign corporation  
•  Taxation of dividend  
•  Assessment and payment of corporate tax  
•  Conclusion 

Tax Administration (Cyprus Revenue Authority)  

• Introduction  
•  Guidance issued by the Cyprus Revenue Authority 
•  Practice notes  
•  Advance tax rulings  
•  Taxpayers’ charter  
•  Taxpayers’ rights in the Taxpayers’ charter  
• Taxpayers’ obligations in the Taxpayers’ charter  
• The legal status of the Taxpayers’ charter 

Tax appeal system  

•  Introduction  
•  The Tax Revenue Appeal Board  
•  The Tax Revenue Appeal Tribunal  
•  Objection with the decision of the Commissioner General of Cyprus Revenue Authority 
•  Conditions for objection  
• Admitting a notice of objection  
• Appeal to the Tax Revenue Appeal Board 
• Appeal to the Tax Revenue Appeal Tribunal  
•  Legal aid and court fees  
• Appeal proceedings at the Tax Revenue Appeal Board and Tax Revenue Appeal Tribunal  
• Enforcement of the decisions of the Board or Tribunal  
•  Conclusion  

Analysis of taxpayers’ rights  

• Introduction  
• Tax must be imposed by law  
•  Right to pay no more than the correct amount of tax  
•  The right to be informed, assisted and heard  
•  The right to be informed  
•  The right to be assisted  
•  The right to be heard  
• The right to privacy and confidentiality  
• The right to appeal  
• Conclusion 

Base erosion and Profit Shifting (BEPS)  

• Introduction  
• Jurisdiction to tax  
• Transfer pricing  
• Leverage  
• Anti-avoidance rules  

Efforts of the EU to counter BEPS  

• Introduction   
• Strengthening the fight against tax avoidance and evasion  
• Setting a common general anti-abuse rule  
• Exchanging information among EU Member States  
• Improving cooperation between EU Member States’ tax administrations  
• Enhancing tax compliance through introducing a Taxpayers’ Charter in the EU  
• Introduction  
• Model Taxpayer Charter  
• Challenges to the Model Taxpayer Charter  
• Model for a European Taxpayers’ Code  
• Summary  

Efforts of the OECD to counter BEPS 

• The OECD actions plans  

Exchange of Information in the OECD BEPS-project  

Assessment of taxpayers’ rights in the techniques used to counter BEPS  

• Taxpayers’ rights in the BEPS project  
• Right to confidentiality  
• Right to appeal  

Who Should Attend

• Financial and banking institutions officers 
• Internal auditors 
• Internal lawyers 
• Company directors 

Training Style

The programme is designed to deliver knowledge and enhance participants’ skills via short lectures, case-studies, practical examples, real-life simulations. Most of the training will focus in assessing participants’ current strengths and weaknesses via formal assessment tools. Participants will also benefit from customised feedback at the end of the programme and take away the knowledge gained to be transferred at their workplace. Most of the training’s time will be invested in analysing a real-life case study that will help participants understand how to solve problems in similar occasions

CPD Recognition

This programme may be approved for up to 14 CPD units in Accounting and Auditing. Eligibility criteria and CPD Units are verified directly by your association, regulator or other bodies which you hold membership.

The Cyprus Bar Association (CyBAR) has confirmed that this programme is accredited for 14 CPD units.

In-house Training

For groups within the same organisation, this course may be customized to meet any specific needs and delivered in-house.