Cross-Border Tax: Substance, Digital Assets & Disputes

Cyprus and Malta experts on substance, residency, crypto, financing and handling tax disputes. The speakers discuss how tax authorities assess economic substance and tax residency for mobile businesses, including Cyprus’s 2026 tax reforms and its 60-day and 183-day residency rules, and Malta’s approach based on intention and supporting evidence. They also cover how crypto and tokenised assets are treated, including the “badges of trade” test, how interest deductions on cross-border financing depend on whether the activity is active or passive, and where businesses commonly miss compliance risks. Finally, they explain how to handle disputes through advance rulings, objections and tribunal review, and why good documentation, governance and early engagement with tax authorities matter.