At the request of a Cayman Island company with a tax residency in Cyprus, we prepared a Tax memo analyzing the tax implications of the proposed restructuring of the group and specifically the merger of the Cayman Island - Cyprus tax resident holding company, being the surviving company, with its Cayman Island subsidiary company. Our analysis included corporate Income Tax, VAT and stamp duty issues for the surviving company in Cyprus following the merger, the taxation of possible dividend distribution by the surviving company to its shareholder and the possibility of offsetting the tax losses of the surviving company after the merger with the other CY tax resident companies of the group.