↳ CYPRUS
European compliance, without European tax burden.
1. Advantages
• 15% Flat Corporate Tax
• Participation Exemption on Dividends
• No Withholding Tax on Outbound Dividends (non-residents)
• No Capital Gains Tax on Disposal of Shares (subject to conditions)
• 65+ Double Tax Treaties
• EU & Eurozone Jurisdiction
2. Utilization
• Holding Companies
• Investment Structures
• Intellectual Property Structures (IP Regime available)
• Trading Companies
• Regional Headquarters
3. Why Cyprus?
Cyprus applies a competitive 15% corporate tax rate and offers participation exemption on qualifying dividend income and capital gains from disposal of shares (excluding Cyprus real estate holding companies). As an EU Member State, Cyprus provides access to EU Directives (Parent–Subsidiary, Interest & Royalties), regulatory transparency, and treaty benefits. Its legal system is based on English common law principles, making it familiar to international investors.
4. Corporate Requirements
The most common legal entity is:
• Private Limited Company (LTD)
Key Features:
• Minimum one shareholder
• Minimum one director
• Company secretary required
• No minimum share capital requirement (commonly €1,000 authorized)
• Registered office in Cyprus mandatory
Annual financial statements must be prepared in accordance with IFRS and audited.
5. Other Requirements
VAT:
• Standard VAT rate: 19%
• Reduced rates: 9% and 5%
VAT registration threshold: €15,600 annual turnover.
6. Compliance & Filing
• Annual corporate income tax return
• Provisional tax payments (bi-annual installments)
• Annual audited financial statements
• Annual return filing with the Registrar of Companies
• VAT returns (quarterly if registered)
Corporate tax return filing deadline generally 15 months after year-end (subject to extensions).
7. Double Tax Treaty Network
Cyprus maintains 65+ Double Tax Treaties, including with:
• EU Member States
• United Kingdom
• United States
• UAE
• Switzerland
• China
• India
This extensive treaty network enhances cross-border tax efficiency.
8. Type of Legal System
Common Law system based on English legal principles.
9. General
Established EU financial center combining competitive taxation, regulatory credibility, and international accessibility.
10. The Choice of a UAE Free Zone Company is a Choice of Tax Efficiency & Global Connectivity
The Choice of Cyprus is a Choice of EU Efficiency & Competitive Taxation
CREATION OF A LIECHTENSTEIN FOUNDATION (STIFTUNG)
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Protect your assets and proceed with your estate planning today by establishing a foundation in Liechtenstein (an ideal option due to its favorable tax regime for Greek tax residents).
Advantages
• 0% Tax
• 0% Tax on distributions
• Ideal to be used with Liechtenstein legal entity
• Minimum Annual Tax ~CHF 1,800
eestablishment of a cyprus international trust (CIT) in Cyprus
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Cyprus is a well-established EU jurisdiction for private wealth structuring, combining a common-law based trust framework with EU credibility and a modern regulatory environment. Cyprus International Trusts (CITs) are widely used for asset protection, succession planning, and family governance, offering strong flexibility and confidentiality (within applicable reporting/registry obligations).
A CIT may be structured so that non-Cyprus sourced income and non-Cyprus assets are generally not subject to Cyprus taxation, subject to the trust’s facts and the tax residence of beneficiaries.
1. Advantages
• Strong asset protection provisions
• No statutory limit on trust duration (post-2012 amendments)
• Potential Cyprus tax neutrality for non-Cyprus income where conditions are met
• Fixed stamp duty commonly referenced at €430 (timely stamping requirement)
• Cyprus resident trustee requirement supports administration and regulatory standing
2. Utilization
• Estate & succession planning
• Asset protection / creditor protection structuring
• Family office and governance arrangements
• Holding of shares / portfolios / international assets
• Philanthropic or purpose arrangements (where structured accordingly)
3. Why Cyprus?
Cyprus offers a familiar common-law trust environment, EU standing, and a trust regime modernized by the 2012 amendments (e.g., removing prior duration limitations and strengthening flexibility).
4. Corporate Requirements
Key eligibility / structural points commonly applied for a Cyprus International
Trust include:
• At least one trustee must be a Cyprus resident
• The settlor must not have been a Cyprus tax resident in the calendar year preceding the year of creation (per commentary on the 2012 amendments)
• Trust deed, trustees, beneficiaries/classes, protector (optional), and governance provisions defined in the trust instrument
5. Other Requirements
• Stamp duty: commonly referenced fixed amount if stamped within the applicable time window
• Trust register: Cyprus has a trust beneficial register maintained by CySEC; registration/beneficial ownership details may be required under applicable rules
• No VAT concept applies to the trust’s mere establishment (VAT is a supplies-of-goods/services regime)
6. Compliance & Filing
• Maintain proper trust records and trustee resolutions
Maintain Accounting records & end of year reports
• Register/update details in the relevant trust register where required
• Tax filings depend on Cyprus-source income and the tax residence of beneficiaries (Cyprus-source income and distributions to Cyprus-resident beneficiaries may trigger Cyprus taxation under general rules).
7. Double Tax Treaty Network
Cyprus has an extensive DTT network; however, treaty access for trusts is fact-dependent (e.g., whether the trust is treated as tax resident / taxable in Cyprus and the treaty counterparty’s approach).
8. Type of Legal System
Common Law system based on English legal principles.
9. General
An established EU trust jurisdiction offering strong structuring flexibility, robust asset protection features, and modernized trust legislation.
10. The Choice of a Cyprus International Trust is a Choice of EU Credibility & Robust Wealth Structuring
Cyprus provides a mature trust framework with strong protective features and potential tax efficiency for international families, subject to proper design and ongoing compliance.
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