At the request of a Cyprus holding company owning a number of shipping companies in Malta and also involved with operational activities for maritime transport we prepared a tax memo in relation to the proposed restructuring scheme of the Group’s shipping activities. Companies involved were registered in Cyprus, Malta and Hong Kong. We analyzed the tax issues entailed following the employment of Cyprus holding company’s personnel by the Hong Kong holding company and specifically transfer pricing risks, the tax implications for employees physically located in Cyprus and receiving salary in Hong Kong due to the absence of DTT between Hong Kong and Cyprus, the possibility of the establishment of a Cypriot branch of Hong Kong company and its eligibility to taxed under the tonnage tax system (TTS) and the tax risks involved upon distribution of funds from Cypriot PE to head office in Hong Kong.