Cyprus tax + corporate + regulatory glossary — 50+ terms explained.

Cyprus collective investment scheme under AIF Law 124(I)/2018. Three vehicles: AIF (CySEC-authorised), AIF-LNP (limited number of persons, ≤50 investors), RAIF (registered, no CySEC pre-authorisation).

Manager of AIFs under AIFM Law 56(I)/2013 (transposing EU AIFMD 2011/61/EU). Internal AIFM (self-managed AIF) or External AIFM (third-party-managed). EU passport via AIFMD Articles 32 + 33.

EU AMLD framework, transposed in Cyprus by Law 188(I)/2007. AMLD6 + AMLR 2024/1624 effective from 2024.

Cyprus Income Tax Law 118(I)/2002 — 0% Cyprus capital-gains tax on disposal of shares + bonds + debentures + qualifying titles. Unconditional (no holding-period / minimum-percentage tests).

Cyprus Income Tax Law 118(I)/2002 (as amended by Law 169(I)/2016) — 80% exemption on qualifying intangible-asset profit under OECD Modified Nexus Approach.

EU Directive 2016/1164 (ATAD I) + 2017/952 (ATAD II). Cyprus transposed: interest-limitation rule (Article 11A), CFC rule (Article 35A), exit-tax + hybrid-mismatch + GAAR.

Cyprus Tax Department-issued binding written ruling under Article 21A ACTL 4/1978. 90-day standard or 21-day expedited. Used for IP Box, M&A, restructuring, TP pre-clearance.

MiCA Regulation 2023/1114 EU-licensed crypto-asset service provider. Cyprus CySEC issues CASP authorisation. EU passport via MiCA Article 65.

Foreign company controlled (≥50%) by Cyprus parent with effective tax rate <7.5% (= 50% of Cyprus 15% rate). Article 35A ITL transposes ATAD I CFC framework. Substance defence available.

Cyprus 20% CGT on disposal of Cyprus immovable property (or shares in property-rich companies >50%). Other share disposals: 0% under Article 9(1)(g) titles exemption.

MiFID II-authorised investment firm under CISARMA Law 87(I)/2017. CySEC supervises. Three capital tiers: €75k / €150k / €750k.

Cyprus 15% standard rate from 1 January 2026 (Law 240(I)/2025, raised from 12.5%). Effective ~3% with IP Box on qualifying income. 20% R&D super-deduction stacks.

OECD framework for automatic exchange of tax information. EU transposition via DAC2 (Directive 2011/16/EU as amended). Cyprus banks + EMIs + brokers report to Cyprus Tax Department; auto-exchange annually.

Cyprus domestic stock exchange. Main Market (regulated) + Emerging Companies Market. Lower-cost listing alternative to LSE / NASDAQ / Euronext for SME / family-business listings.

Cyprus Securities and Exchange Commission. Supervises MiFID II investment firms, MiCA CASPs, AIFMs, UCITS managers, listed companies. Cyprus's primary financial-services regulator.

EU Directive 2018/822 — mandatory disclosure of reportable cross-border tax arrangements. Cyprus transposed by Law 41(I)/2021. 30-day filing window + 5 hallmark categories.

EU Directive 2023/2226 transposing OECD CARF. CASPs report customer crypto-asset transactions to home-state tax authority. Cyprus operational from 1 January 2026; first auto-exchange 30 September 2027.

Cyprus Ltd director / shareholder loan account. Interest-free / below-market loans trigger 9% benefit-in-kind (BIK) deemed interest charged to director's PAYE.

Bilateral tax treaty between Cyprus + foreign jurisdiction. Cyprus has 65+ active DTTs. Most are post-MLI (BEPS Multilateral Instrument) updated with PPT clause.

Earnings Before Interest, Tax, Depreciation, Amortisation. Tax-adjusted EBITDA used for Cyprus Article 11A interest-limitation rule (30% EBITDA cap on net interest deduction).

EU Regulation 2020/1503 — single EU-wide framework for crowdfunding service providers. Cyprus CySEC issues CSP authorisation. €5M project ceiling.

EU electronic identification + trust services regulation (Regulation 910/2014, amended by 2024/1183 'eIDAS 2.0'). QES (Qualified Electronic Signature) legally equivalent to handwritten signature.

Cyprus-CBC-authorised institution issuing e-money under E-Money Law 81(I)/2011 (transposing EMD2 2009/110/EC). €350k capital. Examples: Wise Business, Revolut Business.

Cyprus ESOP four-stage tax framework: grant (no tax), vesting (no tax for options), exercise (PAYE on spread + 50% expat exemption if eligible), sale of shares (0% Article 9(1)(g) titles exemption).

EU General Data Protection Regulation (Regulation 2016/679). Cyprus Personal Data (Processing) Law 125(I)/2018 supplements. Fines up to €20M or 4% global turnover.

Cyprus General Health System. Employee 2.65% + employer 2.9% + self-employed 4% contribution. Mandatory for Cyprus tax residents.

US tax rules apportioning Cyprus subsidiary income to US shareholders. GILTI: §951A IRC (post-2017 TCJA). Subpart F: §951 IRC. Affects US persons owning Cyprus Ltds.

Cyprus Companies Registrar form — annual return + audited financial statements. Annual filing requirement for all Cyprus Ltds. ~€200 standard fee.

Cyprus Companies Registrar form — share-transfer notification. Required for share transfers + must be filed within 14 days of completion.

Institute of Certified Public Accountants of Cyprus. Regulates Cyprus accountants + auditors. Cyprus-accounting-firm authorisation framework.

EU prudential framework for investment firms (Regulation 2019/2033 + Directive 2019/2034). Replaced CRR/CRD for investment firms from 2021. Three classes: Class 1 (largest, CRR), Class 2 (IFR), Class 3 (simplified).

EU Directive 2016/2341 — Institutions for Occupational Retirement Provision. EU pension-fund framework. Cyprus transposed in 2020; supports Cyprus QROPS for UK SIPP transfers.

EU VAT scheme for distance sales of low-value goods (≤€150) imported from non-EU into EU. Cyprus IOSS registration via TaxisNet.

Cyprus regime exempting 80% of qualifying intangible-asset profit (Article 9(1)(l) ITL). Effective ~3% at 15% CIT on qualifying SaaS / software / patented IP. OECD Modified Nexus Approach.

Cyprus personal income tax return. Annual filing for Cyprus tax residents. Due 31 July (electronic via TaxisNet).

Cyprus corporate income tax return. Annual filing by Cyprus Ltds. Due 31 January of the second year following (post-2026 reform).

Cyprus Ltd constitutional document filed with the Registrar. Companies Law Cap. 113 framework. Defines share classes, governance, reserved matters.

EU Regulation 2023/1114 — EU framework for crypto-assets + CASPs + stablecoins. In force from 30 December 2024. Cyprus CASP authorisation by CySEC. Transitional regime ends 1 July 2026.

EU Directive 2014/65/EU — investment-services framework. Cyprus CISARMA Law 87(I)/2017 transposes. CySEC supervises Cyprus Investment Firms (CIFs).

Cyprus Financial Intelligence Unit (Money Laundering Unit). Receives Suspicious Activity Reports (SARs) under Cyprus AML Law 188(I)/2007.

Cyprus tax deduction for new equity introduced (Article 9B ITL 118(I)/2002). Rate = 10-year bond yield + 5% premium (~8-9% currently). 80% taxable-profit cap.

Cyprus Non-Domiciled tax-resident regime. Exempts dividends + interest + rental from Special Defence Contribution (SDC) for 17 years from becoming Cyprus tax resident.

EU VAT Union Scheme for B2C cross-border supplies. Cyprus OSS lets EU sellers report destination-VAT for all 27 member states via single Cyprus quarterly return. €10k EU-wide threshold.

Pay-As-You-Earn income-tax withholding. Cyprus employers withhold + remit monthly to Tax Department. Standard progressive PIT brackets 0-35%.

OECD global minimum tax (15% per jurisdiction) for MNE groups ≥€750M consolidated revenue. Cyprus transposed via Law 165(I)/2024 with QDMTT (Qualified Domestic Minimum Top-up Tax).

Cyprus CBC-authorised payment-service provider under PSD2 transposition (Law 31(I)/2018). Capital €20k-€125k tiered.

BEPS Action 6 / MLI Article 7 anti-abuse provision. Denies DTT benefits where 'one of the principal purposes' of an arrangement was to obtain the benefit. Cyprus DTTs largely MLI-PPT-updated.

Qualified Domestic Minimum Top-up Tax. Cyprus's Pillar Two top-up mechanism (Law 165(I)/2024) — collects 15%-minimum top-up at Cyprus level before other jurisdictions' IIR / UTPR.

Qualifying Recognised Overseas Pension Scheme. UK HMRC-recognised foreign pension scheme. Cyprus IORP-II-registered pension funds offer QROPS-compliant transfers of UK SIPPs.

Registered Alternative Investment Fund. Cyprus AIF vehicle that does NOT require CySEC pre-authorisation — registered with CySEC + must appoint external authorised AIFM. Fastest Cyprus fund launch (1-3 months).

Cyprus tax on dividends + interest + rental. Cyprus-domiciliaries: 5% on dividends (post-2026 reform, reduced from 17%). Non-Dom: 0% for 17 years. Separate from CIT + PIT.

Private contractual agreement between Cyprus Ltd shareholders supplementing M&AA. Covers reserved matters, pre-emption, drag/tag, exit triggers, deadlock, dispute resolution.

Cyprus Tax Department identifier for individuals + entities. Issued on registration. Required for all Cyprus tax filings.

Cyprus Tax Department-issued certificate confirming Cyprus tax residency for specific year + DTA. Required for source-state WHT relief claims + foreign-tax-authority correspondence.

Natural person owning / controlling ≥25% of Cyprus company shares / votes / profit entitlement. Cyprus UBO Register filed with Registrar within 14 days of changes. AML Law 188(I)/2007 framework.

Cyprus standard VAT rate 19%. EU B2B reverse charge mechanism via VIES (VAT Information Exchange System). €15,600 Cyprus VAT-registration threshold.