UK, Cyprus, Greece, Monaco and Luxembourg Tax Advice – Real Estate/Hospitality

Provided overview of the tax regime applicable in the UK, Cyprus, Greece, Monaco and Luxembourg (the “Investment Countries”) including commentary on any particular tax exemptions/relief or tax incentives that could be made available to the Client in the Investment Countries in relation the envisaged investments into residential properties and hotels ;

Provide a summary of Investment Countries tax implications (both direct and indirect) relevant to the Client which will include consideration of:
- Corporate tax
- Withholding tax on income flows (dividends, interest, management charges, if any) from the projects up to the UK where both investors are currently tax resident.
- Capital gains tax implications upon future exit from the investment at each level of any proposed structure; this should include assessment of sale/transfer of shares and land/assets.

Commentary on tax losses and capital allowances, including restrictions on utilisation in the operating entities as well as carry forward rules.

Consideration of the funding (i.e. debt v equity) of the structure and its impact on:
- The tax implications of the structure as a going concern
- The tax implications at time of exit from the structure

Upon providing our comments on the above tax implications we provided tax strategies to minimise or mitigate the tax burden/costs identified with the objective of maintaining a tax efficient structure for the parties concerned. Such review included review of and applicability of the appropriate double taxation treaties and EU Directives to minimise tax leakage through the structure.

We provided considerations around structuring the lending company (i.e. optimising the debt v equity ratio).

We provided high level comments on Transfer Pricing implications at the level of the entities in scope.

We comment on tax implications (direct and indirect) associated with future transfer of shares by the Client, as well as transfer of land/assets.