Corporate Tax
Complete guide to Cyprus corporate income tax at 15% (from 2026): taxable vs. exempt income, trading loss relief, group relief, Pillar Two impact, and the key deductions that keep effective rates well below the headline rate.14 min read · By Nexora Cyprus editorial team · Reviewed by an ICPAC-registered Cyprus tax adviser engaged by Nexora
Quick Summary
Cyprus corporate income tax (CIT) is 15% from 1 January 2026 on worldwide profits of Cyprus tax-resident companies. Key exemptions include dividend income from subsidiaries and capital gains on securities. Effective rates are typically well below 15% due to the IP Box (80% deduction), Notional Interest Deduction, and 120% R&D super-deduction. Pillar Two (QDMTT) only affects groups with consolidated revenue above €750 million.
Cyprus corporate income tax (CIT) is levied on the worldwide income of Cyprus tax-resident companies and on the Cyprus-source income of non-resident companies with a permanent establishment in Cyprus. A company is tax-resident in Cyprus if it is incorporated in Cyprus and managed and controlled from Cyprus — the management and control test requires that a majority of the board of directors exercise their decision-making functions from Cyprus. Full details are available from the Cyprus Tax Department.
The CIT rate is 15% for accounting periods beginning on or after 1 January 2026 (increased from 12.5% under the 2026 tax reform). Despite the rate increase, Cyprus remains one of the lowest CIT jurisdictions in the EU, with effective rates typically well below the headline figure due to a wide range of legitimate deductions and exemptions.
Cyprus has an extensive list of income items that are fully exempt from CIT, which significantly reduces the effective tax burden for holding companies, trading companies, and investment vehicles.
Key CIT Exemptions
| Income Type | Exempt? | Conditions / Notes |
|---|---|---|
| Dividend income (from subsidiaries) | Yes | Anti-avoidance: not from passive foreign income or jurisdictions with effective tax < 6.25% |
| Capital gains on disposal of securities | Yes | Shares, bonds, debentures, options, and other qualifying 'titles' — wide definition |
| Gains from forex (FX) transactions | Yes | Unless from FX trading as main business |
| Income from permanent establishments abroad | Yes (election) | Can elect to exempt PE profits — watch loss offset implications |
| Interest income (non-trading) | Exempt from CIT; subject to SDC | SDC at 30% (domiciled) or 0% (non-dom) |
Business expenses are deductible to the extent they are incurred wholly and exclusively for the production of taxable income. Cyprus follows a broad deductibility approach, with explicit statutory provisions for key categories. Use our corporate tax calculator to model your effective tax rate after deductions.
Trading losses can be set off against other income of the same company in the same tax year, and any remaining losses can be carried forward indefinitely against future profits of the same trade. Cyprus does not allow loss carry-back.
Group relief is available where a Cyprus tax-resident company (or a Cyprus permanent establishment of an EU-resident company) can surrender losses to another group member. A group requires a 75% holding directly or through Cyprus-resident entities. Related-party arrangements within groups must comply with transfer pricing rules and the arm's length standard.
The EU Minimum Tax Directive requires Cyprus to apply a Qualified Domestic Minimum Top-Up Tax (QDMTT) to ensure that large multinational groups (consolidated revenue ≥ €750 million in at least two of the prior four years) pay a minimum 15% effective tax rate on Cyprus-source profits. The OECD Pillar Two framework sets the global minimum standard.
For companies below the €750 million threshold — which is the vast majority of Cyprus companies — Pillar Two is irrelevant as a direct tax obligation. However, companies that are part of large international groups should assess their position carefully, as the QDMTT can apply even where the Cyprus parent is not large if the global group exceeds the threshold.
Pillar Two Threshold
Pillar Two (QDMTT) applies to groups with consolidated revenue ≥ €750 million. Most SMEs, startups, and mid-market businesses in Cyprus are unaffected.
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Disclaimer: This article is for informational purposes only and does not constitute legal, tax, or financial advice. Tax laws change frequently. Consult a qualified Cyprus adviser for guidance specific to your situation. The information on this page is general guidance only and does not constitute legal, tax, accounting, immigration or financial advice. Specific advice should be obtained based on the facts of each case.
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