Tag Archives: Antis Triantafyllides & Sons

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Antis Triantafyllides & Sons advises on the sale of shares in one of Egypt’s fastest growing pharmaceutical companies

Our firm advised the Egyptian American Enterprise Fund (“EAEF”) and its investment manager Lorax Capital Partners with respect to the acquisition of a significant stake in the Cyprus holding company of Orchidia Pharmaceutical Industries, the leading Egyptian ophthalmic generic medicine manufacturer and one of the fastest growing pharmaceutical companies in Egypt.

The firm advised and provided support throughout the transaction. Our team has carried out due diligence reports on the Cyprus holding companies, assisted with the review of sale and purchase agreements and share swapping agreements, drafted the articles of association and assisted with the closing formalities.

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Cyprus Double Tax Treaty developments

The double tax treaties (the “DTTs”) which Cyprus has concluded with Ethiopia, Iran and Jersey have recently entered into force and, as per the provisions of the relevant DTTs, will become effective as from 1 January 2018.

In brief:

1. The DTT between Cyprus and Ethiopia provides for 5% withholding tax on dividends, interest and royalties.

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Cyprus introduces new attractive tax residence criteria for individuals

The Cyprus Parliament has approved in July 2017 an amendment to the Cyprus Income Tax Law, Law 119(I)/2017 (the “Law”) pursuant to which the definition of an individual considered as a Cyprus tax resident has been extended. The amendment is effective as from 1 January 2017.

Before the amendment to the Law, an individual is considered as a Cyprus tax resident if he/she stays in Cyprus for one or more periods exceeding in aggregate 183 days in a tax year.

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Cyprus Tax Authorities introduce guidance for taxation of Intra-Group Financing Transactions

On 30 June 2017, the Cyprus Tax Authorities (the “CTA”) issued a tax circular (the “Circular”) with respect to the new rules for the taxation of back-to-back intra-group financing transactions. The Circular is effective as from 1 July 2017 and follows the application of the arm’s length principle set out in the OECD Transfer Pricing Guidelines.

Earlier this year, the CTA announced that, with effect from 1 July 2017, the application of the specified minimum profit spreads (0.125% – 0.35%) on qualified back-to-back related-party financing transactions will be terminated and the treatment of such transactions is now subject to the Circular.

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ATS first to issue a Court order in favour of Insolvency Practitioner

Our firm was the first one to issue a Court order in Cyprus in favour of an Insolvency Practitioner (Σύμβουλο Αφερεγγυότητας) forcing the creditors of a particular debtor to abide by a Personal Repayment Plan devised by the Insolvency Practitioner. In the course of restructuring of a particular debtor’s debts, the Insolvency Practitioner devised a Personal Repayment Plan for the debtor in question. The Insolvency Practitioner presented the said Personal Repayment Plan to the debtor’s creditors but this was rejected by one particular creditor. Our firm assisted the Insolvency Practitioner to rely on the recently introduced insolvency legal framework and managed to secure in favour of the Insolvency Practitioner a Court order whereby the Personal Repayment Plan was imposed on the rejecting creditor.
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Antis Triantafyllides & Sons advises EBRD on photovoltaic park financing

Our firm advised the European Bank for Reconstruction and Development (“EBRD”) on a Euro 10 million financing for the construction, development and operation of five solar photovoltaic parks in Cyprus, with a total capacity of 11.9MW. The parks are located across the island at Paliometocho, Dhali, Frenaros, Nisou and Malounta.

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Antis Triantafyllides & Sons advises EBRD on photovoltaic park financing

Our firm advised the European Bank for Reconstruction and Development (“EBRD”) on a Euro 10 million financing for the construction, development and operation of five solar photovoltaic parks in Cyprus, with a total capacity of 11.9MW. The parks are located across the island at Paliometocho, Dhali, Frenaros, Nisou and Malounta.

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Antis Triantafyllides & Sons advises Hellenic Bank on establishing debt recovery servicing JV

Our firm acted as local legal advisor of Hellenic Bank Public Company Ltd on the establishment of a joint venture with the APS Holding Group for the management of the real estate assets and the servicing of a portfolio of non-performing exposures of Hellenic Bank.

The transaction will result in the creation of the first debt servicing platform in Cyprus.

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New Improved Criteria for Citizenship by Exemption

On Friday, 16th of September 2016, the Cyprus Government revised the economic criteria and conditions of the Scheme for Cyprus citizenship by investment (the “Scheme”) so as make it more attractive for non-Cypriot investors wishing to acquire Cypriot Citizenship.

The most important change is that an applicant is, now, only required to make an investment of €2.000.000, instead of €5.000.000 as had previously applied.  The required investment can be in real estate, tourism and infrastructure projects or in shares or financial instruments of companies operating in Cyprus, including investment in Alternative Investment Funds. The Scheme also allows the investment in Cyprus Government Bonds for a maximum amount of €500.000.

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International Trusts In Cyprus

In July 1992, Cyprus enacted the International Trusts Law 69(I)/92 (the “Law“). The Law regulates the establishment and administration of international trusts and is designed to complete the spectrum of services the island offers as an international financial centre. It should be noted that, since Cyprus is a common law jurisdiction, the concept of trusts has always been part of Cyprus law. Thus, the object of the Law has been to modernise and update the existing legal framework in order to reaffirm the position of Cyprus as a significant trust jurisdiction. As of 23 March 2012, the Law has been extensively amended in order to bring the same in line with the laws of other jurisdictions, allowing for the creation of international trusts. More…

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