The Management and Control Test — Taxation of Cyprus and Foreign Companies

I. THE LAW

II. MANAGEMENT AND CONTROL — DEFINITION

III. ENGLISH LAW CONCERNING THE RESIDENCY OF A COMPANY

IV. INTERPRETING THE MANAGEMENT AND CONTROL TEST

V. ANALYSIS

A. Where is a company tax resident according to the management and control test and When is a company tax resident of Cyprus?

B. Who exercises the management and control?

C. Factors identifying the location of the management and control exercise

D. How the management and control must be exercised in order for a company to be considered as a tax resident of Cyprus?

E. Double Tax Treaties — Their impact on the residency issue of Cyprus companies

VI. INLAND REVENUE APPROACH

VII. CONCLUSION — FINAL SUMMARY

Mr. Kinanis is a practicing Lawyer in Cyprus with 35 years experience in the Law profession. Author of various articles on Legal and Tax matters.

Mr. Kinanis is a practicing Lawyer in Cyprus with 35 years experience in the Law profession. Author of various articles on Legal and Tax matters.