Multi-disciplinary. Multi-jurisdictional. This is what CYLON is here to fill.

The gap in professional service provision today is the limit on jurisdictions or disciplines. Regulatory silos stop us from doing our best for the client.

This inefficiency of the professional service provision market is the reason we decided to engage in a much aspiring attempt to pool on the knowledge hidden behind regulatory walls. CYLON International Alliance is a venture of its own despite the independence of its members.

Its managed professionally, organized in a multilevel pyramid form, engaged in monthly events and joint member campaigns and continuously developing discipline and jurisdiction members knowledge.

The target is simple, offer real multi-discipline and multi-jurisdictional value to members clients. Wish us good luck.

In a recent article of the Economic Times, published on the 19th of April, is reported that the Ministry of Finance is requesting for a renegotiation of the India – Mauritius Double tax treaty. More specifically the article reports that:

“The finance ministry has written to MEA for renegotiation of the tax treaty to ensure exchange of information of banking transactions and assistance in tax matters,” Central Board of Direct Taxes chairman Sudhir Chandra told reporters. Indian tax authorities are keen to introduce provisions in the treaty that will restrict its benefits to genuine investors through a limitation of benefit clause.Find the link here.

Its clear that the double tax Treaty with India will be actively pursued, for renegotiation. The sparing provisions of the treaty and the capital gains protection provided for therein are two main reasons for concern. Although the treaty between India and Mauritius is not the only treaty with such provisions (Cyprus – India treaty is the other), it seems that the heat is on Mauritius, mainly due to the fact that Mauritius is generally perceived as the traditional route for investments to India.

Although the purpose of a Double Tax Treaty is to enable and facilitate certainty in investments into a country, the abuse of the provisions of a treaty may lead to facilitating the rerouting of funds or even the avoidance of otherwise payable tax. In the occasion of Mauritius it seems that due to the continuous use of the regime the stakes are really high and the heat will continue. As Economic Times report in the same article:

The abuse of tax treaty to avoid taxes by investors of a third country is a major concern of tax authorities. India loses more than $600 million every year in revenues on account of the DTAA with Mauritius, as per some available estimates. India has also entered into information exchange agreement with countries such as Switzerland and tax havens such as Bahamas and British Virgin Islands to allow it to get crucial data on tax evasion in specific cases.

Today we publicly start a new journey in the world of international business. We concentrate on India. Our extensive experience in the field of International Tax & Structuring and few months of work with our existing India clients convinced us that Cyprus has lot more to offer to India, than its current contribution. The current developments in the field of tax and structuring, make it clear that Cyprus is probably the best jurisdiction for both Inbound and Outbound investment in relation to India. Cyprus will, in the coming years become THE GATEWAY OF INDIA TO EUROPE and THE GATEWAY OF EUROPE TO INDIA. We will make sure that LLPO is there, in this change, as we did several times in the past with other jurisdictions.

LLPO together with our UK associates Healys LLP and a team of Financial Services experts organize an introductory and networking visit to India titled INDIA – UK – CYPRUS: THE INVESTMENT CONNECTION. This visit will be the first of a series of visits organized for 2011. We will be in India from 2nd to 9th of April. We will be holding two open (but RSVP) networking events, one in New Delhi on the 4th of April and one in Mumbai on the 6th of April. Further we will be meeting a number of professionals and businesses interested in international tax and corporate structuring or to review possible opportunities for corporate finance.

Our India – Cyprus Group is combining the necessary knowledge and expertise of our associates in 3 jurisdictions to offer turnkey solutions to our clients interested in INBOUND and OUTBOUND Investment to India. LLPO’s extensive expertise in international structuring is the cornerstone of our inbound – outbound investment structuring service. International Tax Structuring is integral part of our services to our international clients. Investing in India or getting out of India always involves international tax issues to be considered.

Through our associated firms Beaufort International Associates Limited and the Share Republic.com Limited, both FSA Approved firms, we can work on our clients requirements for capital markets fund raising, mainly through United Kingdom. Further to that, our close working relation with the Brook Group, an India specific corporate finance firm opens up other financing possibilities to our clients.