An EU member state — not a tax haven — with a 15% headline corporate tax, an IP Box that drops the effective rate on qualifying IP income to approximately 3%, 0% withholding tax on dividends, interest and royalties paid abroad, and 65+ double tax treaties. Structures that withstand HMRC, IRS and EU scrutiny.
Pre-exit shareholders planning a share sale in 2–5 years who want 0% Cyprus CGT on disposal proceeds rather than a home-country charge.
Groups with intellectual property spread across several countries who want to consolidate under a Cyprus IP Box structure for a approximately 3% effective rate.
High-net-worth individuals with dividends, interest, or rental income who want to use non-dom status to eliminate SDC (5% on dividends, 17% on interest) and optimise overall tax.
Businesses currently bearing effective corporate tax above 15% who want to legitimately restructure using Cyprus's holding layer, NID, and IP Box.
British and European founders affected by the abolition of non-dom regimes at home who need a compliant new structure anchored in an EU jurisdiction.
Corporate groups using Cyprus finance companies to benefit from 0% withholding tax on interest, participation exemption on dividends, and 65+ tax treaties.
What we advise on
Designing optimal Cyprus holding company structures to maximise the participation exemption on dividends, eliminate withholding taxes on distributions, and leverage Cyprus's 65+ tax treaty network for group income flows.
Structuring IP-owning entities to qualify for the Cyprus IP Box — achieving an effective approximately 3% tax rate on qualifying IP income. Nexus fraction analysis, qualifying expenditure mapping, and advance tax ruling preparation.
Advisory for founders relocating to Cyprus under the Non-Domicile regime — structuring personal income flows to eliminate SDC on dividends and minimise overall effective tax rates. 2026: SDC on dividends reduced from 17% to 5% for domiciled residents; DDD abolished; stamp duty abolished.
Structuring for tax-efficient exits — whether a business sale, secondary buyout, IPO, or investment disposal. Cyprus's broad securities exemption eliminates CGT on qualifying share disposals.
Arm's length structuring and documentation for intragroup transactions. Preparation of Local Files and compliance with the 2026 reform's updated thresholds — €5M for financing, €1M for other controlled transactions.
Advising on restructuring existing multinational groups to incorporate a Cyprus holding or IP company — including tax-neutral migrations, share swaps, and mergers under the EU Merger Directive.
We understand your current structure, business model, revenue streams, and objectives. No generic advice — every engagement starts with understanding your specific situation.
We design a bespoke Cyprus tax structure tailored to your circumstances, analysing holding layers, IP ownership, director tax residency, and substance requirements.
We coordinate incorporation, UBO registration, nominee arrangements (if applicable), and all statutory filings. You receive a complete, operational structure.
Tax structuring is not a one-time event. We provide ongoing advisory as your business evolves, regulations change, and new planning opportunities arise.
Tax structuring engagements are scoped individually. Below are indicative ranges — contact us for a fixed-fee proposal.
Review of existing structure, identification of inefficiencies, and written recommendations report.
End-to-end design and implementation of a new group structure including IP holding, financing, and intercompany agreements.
Annual structure review, transfer pricing maintenance, regulatory monitoring, and proactive planning updates.
Engagement scope confirmed in writing after a free 30-min call. From €3,699 + VAT (formation). Full schedule at /pricing. View full pricing guide →
We handle most of the heavy lifting, but the following information and documents are needed to scope and execute your restructuring.
EU GAAR and treaty anti-abuse clauses can deny benefits; courts increasingly require genuine economic activity. Structures built on paper alone are unwound by tax authorities.
Both Cyprus and the source country will challenge the transfer. A transfer pricing analysis and independent valuation is essential to defend the transaction.
If a company's 'mind and management' is demonstrably elsewhere, it is tax resident elsewhere regardless of where it is incorporated. Board minutes, local directors, and records matter.
Moving assets or changing residence can trigger crystallisation events in the UK, Germany, Israel, and other jurisdictions — creating an immediate tax bill before any benefit is realised.
Tax law evolves. Pillar Two, ATAD updates, and domestic rule changes can erode benefits without notice. Annual structure reviews are essential to maintain compliance and efficiency.
Often used alongside tax structuring
Every structure we design has documented substance, defensible commercial purpose, and clean DTT principal-purpose-test alignment. If a successful tax-authority challenge invalidates our methodology purely because of our own error, we redo the work at no cost.
Engagements coordinated with ICPAC-registered Cyprus tax advisers and Cyprus Bar Association member-firm lawyers. MOKAS-aligned under Cyprus AML Law 188(I)/2007. See our editorial standards and disclaimer.
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