1. CYPRUS - Basic Concepts of Company’s Law and Tax Legislation

37. THE USE OF A CYPRUS HOLDING COMPANY FOR TAX PURPOSES –SCENARIO 1 Non resident Shareholder Cyprus Holding 0% tax jurisdiction company No SCDT taxes on dividends paid to non residents The dividends paid will not be subject to taxation under Income tax law or under SCDT although the tax burden is significantly lower, the income the subsidiary company derives from activities do not lead to more than 50% trading income

40. Holding investments in other European countries SCENARIO 3 Foreign Shareholder Cyprus Company UK Manufacturing company Dividend paid with 0% withholding Tax Dividend paid with 0% withholding Tax

45. ROYALTY STRUCTURE: Trademark. Patent Offshore company Cyprus company Italian Company Greek Company Legal ownership Beneficial ownership License Any other EU or DDT Country SUBLEASING

47. Holding property real estate companies SCENARIO 5 Foreign Shareholder Cyprus Holding Company Russian Property Holding Company Dividends paid With zero withholding Tax Dividends paid with 5% Withholding tax Income from property Taxed in Russia No tax on dividend income