Kinanis LLC prepared a tax analysis, including also a DAC6 analysis, of a proposed plan for the restructuring of Loan Promissory notes (LPNs) possessed by a Cyprus company. 

We have evaluated the proposed options by the client from the Cyprus tax perspective including the transfer of LPNs to another company of the group as a financial aid or a payment of dividends in kind, the incorporation of a new CY company and transfer the LPNs as a share capital contribution etc.