Overview

This seminar provides a practical and structured overview of international tax concepts that affect Cyprus-based groups and inbound/outbound structures. It covers the interaction between domestic rules and double tax treaties (with emphasis on the OECD Model Tax Treaty and key articles), relevant EU tax directives and their Cyprus implementation, an outline of OECD/G20 Pillar Two (Global Minimum Tax) rules and compliance mechanics, and recent international tax developments impacting business planning and risk management.

Importance of the Seminar

International tax rules are evolving rapidly due to increased transparency, anti-avoidance measures and coordinated reform initiatives (including BEPS and Pillar Two). Cyprus businesses and advisors must understand how treaties, EU law and global minimum tax rules interact with Cyprus domestic provisions to assess tax exposure, structure cross-border activities, manage withholding tax and permanent establishment risk, and meet expanding documentation and reporting requirements. Targeted training helps professionals identify common international tax pitfalls early, respond to audits and information requests, and provide informed, compliant advice in a changing environment.

Learning Objectives

By the end of the seminar participants will be able to:

• Explain core international tax building blocks (residence and source, nexus concepts, corporate vs withholding taxes) and how they typically apply to Cyprus-based cross-border structures.
• Navigate the OECD Model Tax Treaty framework: treaty interpretation, tie-breakers, permanent establishment, business profits, dividends/interest/royalties, capital gains, and relief from double taxation.
• Identify the key EU tax directives relevant to Cyprus (e.g., Parent-Subsidiary, Interest & Royalties, Merger Directive, ATAD I/II, DAC reporting) and the practical implications for structuring and compliance.
• Outline the architecture of Pillar Two (Global Anti-Base Erosion rules): scope and thresholds, effective tax rate concept, top-up tax, and the main charging rules (IIR/UTPR/QDMTT) at a high level.
• Apply the above concepts to common scenarios (inbound/outbound payments, treaty relief and withholding tax planning, PE risk, hybrid mismatches, substance and documentation) and recognize recent international tax developments and risk areas.

Description of candidate for participation

Tax advisors, accountants, auditors, CFOs/financial controllers, corporate lawyers, business advisors, and professionals involved in cross-border structuring, compliance and reporting.

7 CPDs

Upon successful registration, participants will receive the seminar link via email.