A Cyprus Company can own equipment and lease it to a high-tax country entity (HTCE).
Such an arrangement allows the HTCE entity to take advantage on the leasing payments. The equipment may come into the ownership of the Cyprus Company under a sale and lease back agreement with the HTCE entity.
A HTCE can sell its already depreciated assets to a Cyprus Company. The Cyprus Company is entitled to capital allowances on these newly acquired assets and will charge a leasing fee to the original owner. Such an arrangement will reduce the taxable profit in the country of the original owner.