Cyprus

 

Why incorporate in Cyprus?

For non-resident company owners in Cyprus, Cyprus is a tax-haven (i.e. no corporate taxes).  The following is a list of incentives for incorporating in Cyprus:

  • Member of the European Union.
  • An IBC will pay no taxes if it is not considered to be resident in Cyprus. This is often the case when its management and control is outside Cyprus.
  • A non-resident IBC will not be able to obtain a Cyprus Tax residence certificate and therefore cannot utilize the double-tax treaty network.
  • No withholding tax on dividends distributed to non-resident shareholders of Cyprus Companies.
  • Profits earned from a permanent establishment abroad are fully exempt from corporation tax.
  • Profits from the disposal of shares are not taxable for all Cyprus tax residents.
  • Cyprus holds no restriction in the carry-forward of tax losses. They can be carried forward indefinitely to be set-off against future profits.
  • Group relief is available whereby losses from a company can be set off against taxable profits of other companies in the same group.
  • Reorganizations, amalgamations, mergers and acquisitions of companies can be effected without any tax implications.
  • Exemption from capital gains tax, except on sale of immoveable property situated in Cyprus (ex. Office buildings)
  • No exchange control restrictions

Cyprus also holds strict confidentiality policies.  We strongly advise all clients to assign a nominee director when incorporating in Cyprus.  Cyprus authorities have no direct access to bank information and court orders are required in order to get said access as bank employees are bound by secrecy by section 3 of the Central Bank Law 37 of 1975.

UK NON-RESIDENT COMPANIES

A company incorporated in a foreign country is considered to be a tax resident of Cyprus if it is managed and controlled in Cyprus. A foreign company to be managed and controlled in Cyprus is expected to have the majority of directors to reside in Cyprus and to hold Board Meetings in Cyprus .  A UK register company managed and controlled from Cyprus and with activities outside UK will not be taxed in the UK but it will be considered a tax resident of Cyprus.  The UK Company will be registered in Cyprus with the Registrar of Companies as a foreign company and with the tax authorities as a tax resident of Cyprus.  As a company managed and controlled in Cyprus said company is subject to 10% corporate tax.

INVESTMENT COMPANIES

A Cyprus IBC can be used as an investment company financing various projects internationally belonging to the same group. The advantages of a Cyprus Investment IBC are the following:

Interest income
Interest income of investment companies is considered to arise from the ordinary activities of the company and is subject to 10% corporation tax.

Dividends distributed
No withholding tax on dividends distributed to non-resident shareholders of Cyprus Companies.

Interest paid
No withholding tax on interest paid by a Cyprus Company to non-resident creditors.

Interest received
Cyprus has concluded tax treaties with more than 40 countries worldwide. Interest Income paid to Cyprus benefits from the low withholding taxes from countries with which Cyprus signed Tax Treaties.

For example interest is paid to Cyprus from Russia, Ukraine, Austria, Ireland, Norway, and South Africa with zero withholding taxes.

CYPRUS RESIDENT COMPANIES

Basis of taxation
A company incorporated in Cyprus is considered to be a tax resident of Cyprus if it is managed and controlled in Cyprus . A company to be managed and controlled in Cyprus is expected to have the majority of directors to reside in Cyprus and to hold Board Meetings in Cyprus .

Corporation tax
Resident companies are subject to corporation tax at the rate of 10% which is the lowest corporate tax rate in the entire European Union.

Dividends distributed
No withholding tax on dividends distributed to non-resident shareholders of Cyprus Companies.

Interest paid
No withholding tax on interest paid by a Cyprus Company to non-resident creditors.

Double Taxation Treaties
Cyprus has concluded tax treaties with more than 40 countries worldwide. Apart from that, a Cyprus company, being an EU-based entity, is entitled to the benefits of the EU Parent-Subsidiary directive and the EU Interest and Royalty directive, under circumstances providing for withholding tax exemption for interest, dividends and royalty payments made by companies in other EU-member states to a Cyprus company.

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