Ms Elena Christodoulou

Elena Christodoulou

Lawyer biography

Elena Christodoulou was born in Limassol, Cyprus.

She obtained a LLB (Honours) degree in law at University of Surrey in the UK in 2010 and was awarded a scholarship for all three years of attendance, followed by an LLM in International Commercial Law at University of Cardiff in 2011. She was admitted to the Cyprus Bar in 2012.

She speaks English and Greek.

Main areas of practice:

Corporate and commercial law


Updates

Corporate Tax

Tax incentives for start-ups
Cyprus | 27 September 2019

Innovation and entrepreneurship are heavily sought after by countries looking to ameliorate and modernise their economies. Cyprus is no different in this respect and has prioritised creating a vibrant landscape which addresses the needs of start-ups and their investors. The defining features of the Cypriot system are its IP box regime, notional interest deduction, alternative investment funds and various tax incentives which can be coupled with research and development and innovation.

EU directive on administrative cooperation in field of taxation amended
European Union | 16 August 2019

The European Union has added further impetus to its objective of providing greater transparency with regard to harmful tax practices through an amendment to EU Directive 2011/16/EU. The directive has introduced the mandatory reporting of cross-border arrangements that are indicative of potentially aggressive tax planning. The relevant disclosure requirements must be followed by intermediaries and, in some instances, taxpayers.

Response to EU Anti-tax Avoidance Directive
Cyprus | 14 June 2019

The House of Representatives recently approved legislation implementing the EU Anti-tax Avoidance Directive in Cyprus with the aim of improving the resilience of the internal market against cross-border tax avoidance practices. The new legislation has once again demonstrated the government's commitment to supporting international efforts to tackle tax avoidance practices.

Reference rates for notional interest deduction for 2019
Cyprus | 15 February 2019

Article 9(B) of the Income Tax Law 2002 (as amended) provides for a notional interest deduction for tax purposes on new equity capital injected into companies and permanent establishments of foreign companies on or after 1 January 2015 to finance business assets, calculated by applying a reference rate to the new equity. The Tax Department recently announced the 10-year government bond yields for 31 December 2018, which will be used as the basis for the notional interest deduction for the 2019 tax year.

Amendments to Cyprus-San Marino double tax treaty enter into force
Cyprus | 11 January 2019

The Tax Department recently announced that the procedures for ratifying the protocol amending the Convention on the Avoidance of Double Taxation between Cyprus and San Marino have been completed. The protocol, which entered into force on 27 June 2018, replaces the text of Article 25 of the convention with the text of the corresponding article of the Organisation for Economic Cooperation and Development Model Convention 2014.

Amendments to Cyprus-Mauritius double tax treaty enter into force
Cyprus | 21 December 2018

The Cyprus Tax Department recently announced that the procedures for ratification of the protocol dated 23 October 2017 amending the Convention on the Avoidance of Double Taxation between Cyprus and Mauritius have been completed, and that the protocol entered into force on 2 May 2018. The protocol replaces the text of Article 27 of the convention with the text of the corresponding article of the Organisation for Economic Cooperation and Development Model Convention 2014.

Taxation of insurance agent earnings
Cyprus | 21 September 2018

The Tax Department recently issued a circular clarifying the taxation of insurance agent earnings. A representative of an insurer who is not in an employment relationship with that insurer will be treated as a commercial enterprise whose revenue is derived from fees or commissions for the conclusion of insurance contracts. If their annual revenue exceeds €70,000, the intermediary must maintain accounting records and prepare audited financial statements.

Tax Department aims to streamline payment of tax liabilities
Cyprus | 06 July 2018

One of the Tax Department's main priorities is to streamline and modernise its processes and make it more convenient for taxpayers to deal with the department by facilitating the electronic submission of tax returns and payments, thus removing the need to visit a tax office. The electronic submission of income tax and value added tax returns is now mandatory and the department is undertaking a large-scale public information programme to help taxpayers make the change.

New double tax agreement between Cyprus and Andorra
Cyprus | 29 June 2018

Cyprus and Andorra have recently signed a double tax agreement, which is closely based on the latest Organisation for Economic Cooperation and Development Model Convention. The agreement includes a preamble which makes clear that it is not designed to create opportunities for double non-taxation or reduced taxation through evasion or avoidance, as well as a principal purpose test-based general anti-avoidance rule.

New Cyprus-Luxembourg double tax agreement enters into force
Cyprus | 22 June 2018

The double tax agreement between Cyprus and Luxembourg recently entered into force. It will apply to income arising from 1 January 2019 with regard to taxes deducted at source and for tax years beginning on or after that date for other taxes. The agreement includes a preamble which makes clear that it is not designed to create opportunities for double non-taxation or reduced taxation through evasion or avoidance and a principal purpose test-based general anti-avoidance rule.

Domestic law aligned with EU directive on mandatory automatic exchange of tax information
Cyprus | 11 May 2018

The recently introduced Law 33(I)/2018 amends the Law regarding Administrative Cooperation in the Field of Taxation 2012 to 2017 in order to align domestic law with EU Directive 2016/881/EU, which amended EU Directive 2011/16/EU on administrative cooperation in the field of taxation. The new law requires ultimate parent entities of multinational enterprises resident in Cyprus for tax purposes to file country-by-country reports within 12 months of the end of each fiscal year.

Reporting of advance cross-border rulings
Cyprus | 11 August 2017

In order to ensure compliance with the EU directives on the compulsory automatic exchange of information in the field of taxation – in particular, in advance cross-border rulings – the Cyprus Tax Department recently launched an initiative to gather information regarding cross-border decisions issued, modified or renewed between 2012 and 2016 (inclusive).

Double tax agreement between Cyprus and Jersey enters into force
Cyprus | 21 April 2017

The double tax agreement between Cyprus and Jersey recently entered into force following completion of all the requisite ratification procedures. It will take effect with regard to taxes withheld at source in respect of amounts paid or credited on or after January 1 2018 and for other taxes in respect of tax years beginning on or after that date. The new agreement applies to taxes on income and gains from alienation of movable or immovable property.

Implications of anti-avoidance amendments to EU Parent-Subsidiary Directive
Cyprus | 12 September 2014

Cyprus transposed the EU Parent-Subsidiary Directive into domestic legislation when it updated its tax laws in preparation for EU membership in 2004. The Income Tax Law and the Special Contribution for the Defence of the Republic Law provide a liberal system of double taxation avoidance, which also extends to non-EU countries, as the tax laws treat all non-residents of Cyprus in the same way.

Department clarifies five-year restriction on carry-forward of losses
Cyprus | 26 July 2013

The Inland Revenue Department recently issued a circular clarifying the practical application of the new five-year limit for carrying forward losses for relief against future profits. For the 2012 tax year and subsequent years, only losses incurred in the 2007 tax year and later years are available for relief against taxable income. Relief is no longer available for unutilised losses relating to 2006 and earlier years.

Ruling clarifies taxation of advances to directors and shareholders
Cyprus | 15 February 2013

Under the arrangements for the taxation of loans to directors and shareholders, a physical person who maintains a debit balance in the books of a company in which he or she is a shareholder or director is deemed to enjoy a benefit equivalent to 9% a year on the debit balance. However, a recent tax authority ruling confirms that if the individual concerned is not resident in Cyprus, there will be no liability to tax.

New law increases power of authorities to disclose information
Cyprus | 01 February 2013

One of the recent amendments to the tax and company laws was the introduction of the amending Assessment and Collection of Taxes Law, which aims to facilitate the exchange of information in the field of taxation. Among other changes, the tax authorities can now refrain from informing persons when they are the subject of any tax investigation process if they consider that it might jeopardise the effectiveness of the investigation.