The Landmark judgment C-196/04 – Cadbury Schweppes plc, Cadbury Schweppes Overseas Ltd v Commissioners of Inland Revenue, judgment of 12.9.2006, dealt extensively with the need to circumvent wholly artifically arrangments aimed predominantly at the creation of subsidiairies with little or no substance in low-tax jurisdictions. In assessing controlled foreign companies (“CFC”) rules, one has to look at both subjective as well as objective evidence, to ascertain whether CFC physically exists in terms of premises, staff and equipment to ensure that the incorporation of the subsidiary truly reflects an economic reality.
Investors who are tax resident in jurisdictions which apply particularly severe CFC rules are minded on the necessity to create “substance” to subsidiaries or permanent establishments set up in other jurisdictions to circumvent challenges from the resident fiscal authorities. Substance and effective management and control may be ensured cumulatively through a series of provisions, from local board directors, to regular board meetings, opening of local bank accounts etc; However, as shown in Cadbury Schweppes, these measures alone may not be enough to prove presence and clout in other jurisdictions, which is why the use of serviced offices is such an important factor in tax planning today.
Serviced office space combine the provision of tangible facilities, aiding logistical planning with the tax planning of substance and effective management and control (precisely the premises, staff and equipment) set forth in the Cadbury Schweppes Judgment. The Focus Business Services group has devised an optimum and unbranded serviced office package in the most prestigious street of Nicosia, Cyprus in the heart of business district, within walking distance from all major commercial banks and business centre. Hosted in Severis House, serviced office space is available in solutions designed to fully satisfy every professional, with diversified packages from private suites to open workstations. Complementing the optimum location and discrete set-up, are state of the art modern telecommunication facilities, with the latest technologies available in high-definition video-conferencing and internet facilities. Up to sixteen (16) individual participants may participate in these conference calls, thereby ensuring that decisions may be resolved in the most effective and swift manner possible.
In-house management ensures better management of adminstrative and clerical services, and assisting yourself and your clients. Although located in central Nicosia, undergound parking as well as public parking are available within less than thirty metres from the building, with CCTV and security facilities for additional peace of mind. Our offices are designed to facilitate the working experience of the discerning professional with seamless and flexible business solutions, perfect for multinationals, small and medium sized enterprises, but even for freelance professionals and consultants, who wish to have logistical equipment on main street Nicosia within walking distance of their clients.
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