Cyprus

Key Corporate Information

1 Corporate
Tax Rate
12.50%

As above

2 Substance
Requirements

The management and control of the company must be exercised in Cyprus in order for the Company to be tax resident in Cyprus. The Directors must be qualified

3 Withholding
Tax
  • No WHT on either dividends or interest paid out of Cyprus to non-Cyprus tax resident entities or individuals
  • No WHT on royalties paid to non-residents of Cyprus for rights not used within Cyprus
  • Royalties earned on rights used within Cyprus are subject to WHT of 10%
  • DTT’s need to be consulted in order to determine the WHT on a case per case basis
4 Participation
Holding Exemption

Tax exemption of foreign dividend income

5 Number of Double
Taxation Treaties

More than 60

6 Time to
Establish Company

3 working days

7 Audit
Requirement

Audit is required

8 Filing
Requirements

Financial statements of the company must be filed annually

9 Stamp Duty on
Transfer of Shares

No Stamp Duty

10 Shareholder Information
Publicly Available

No

11 Other
Beneficial Factors

Notional Interest Deduction – Corporate taxation rate can be further reduced. A corporation could achieve an effective tax rate of 2.5%

Exempt income – The following source of income (subject to conditions) are exempt from corporate income tax:

  • Dividend Income
  • Interest income, excluding income arising in the ordinary course of business which is taxed under corporation tax
  • Foreign Exchange (FX) gains with one exception
  • Trading in foreign currencies and related derivatives
  • Gains arising from the disposal of Securities