ZRK Advisor Limited Liability Company was established in March 1998 and is entering into the register of the National Chamber of Statutory Auditors in Warsaw under the number 1780.
The company has full liability insurance in respect of its activities.
NIP: 644-28-06-499
KRS: 0000115632
advisor Business activity via Cyprus Financial Simulation
Financial Simulation PDF Print E-mail

The examples of the benefits received from the transfer of the management or advisory center of the Polish company established in the territory of Cyprus.
For the purposes of the model assumptions were adopted: the company out of Poland (A) receives income at the level of 5 million PLN year. Planned order it by the Cypriot company (Cyp-Pol) a fee for management services reaches 90 percent of revenue (4.5 million PLN). Being the owner of the Cyprus, company can be both current shareholder of Polish and Polish company itself.
Other assumptions for the model predict that:

  • annual cost of the Cypriot company, taking into account ongoing maintenance, the cost of its assumptions and the additional costs associated with the use of the activity amounts to 22 thousand PLN,
  • tax rate in Poland is 19 percent,
  • the basic rate of tax income in Cyprus is 10 percent,
  • dividends paid by a Cypriot company to a Polish company and any other company with headquarters in the EU will, in principle, effectively exempt from income tax.

Lp

Position, with annual data

Example (PLN)

1

Output Polish company's income (A)

5 000 k

2

Corporate Income Tax in Poland, charged on the remaining 10 percent of income (the rate of 19 per cent)

95 k

3

Revenue Cyp-Pol

4 500 k

4

The cost of Cyp-Pol

22 k

5

Corporate Income Tax in Cyprus (10 per cent stake)

447,8 k

6

Dividend

4.030 k

7

The sum of taxes in Poland and Cyprus, and the additional costs of operating the structure of the Cypriot

564,8 k

8

Corporate Income Tax in Poland from all income without the use of the structure (the rate of 19 per cent)

950 k

9

Savings (tax benefit)

385,2 k

10

Effective tax rate structure

11.3%

At the Cyprus company's fixed operating costs, the efficiency of the tax structure is improved by increasing the amount of mutual trade.

Below is a diagram assuming that shareholder and the founder of the Cypriot company is a Polish company that uses its services. In this case, the remuneration paid Cyp-Pol shall be transferred without tax to the Polish company in the form of dividends.

For 5 millions, tax income benefit is approximately 385.2 thousand PLN

What's interesting - the Cypriot-owned company may be the holder of the shares in Polish or Polish company itself, but not only. Structure can be used by the group of managers (managing managers who manage the Polish company) by optimizing the taxes of the board members.

The above simulation is merely illustrative.
 
Content View Hits : 154237