Cyprus 2026 — checklists, timelines, desk-references in one place.

The headline 2026 reform package in 10 bullets — the single deliverable everyone evaluating Cyprus needs in 2026.

• Standard CIT raised from 12.5% to 15% (Law 244(I)/2025) effective 1 January 2026.
• IP Box 80% exemption preserved → effective approximately 3% on qualifying SaaS / software / patent income.
• The additional 20% R&D deduction covers qualifying expenditure incurred in 2025–2030. It excludes expenditure on an eligible intangible asset for which IP Box has applied in any year, including the current year (Article 9(1)(d)).
• Stamp Duty Law (Law 19/1963) repealed in full (Law 239(I)/2025) — €0 stamp duty from 2026.
• Crypto: 8% income-tax rule for qualifying disposal gains under Article 20E, with a mining exclusion and same-year loss limits.
• SDC on dividends for Cyprus-domiciled residents reduced from 17% → 5%; Non-Dom 0% preserved.
• Tax-loss carry-forward extended 5 → 7 years.
• Pillar Two GloBE rules applied to MNE groups ≥ €750M (Law 165(I)/2024) with Cyprus QDMTT.
• DAC8 crypto-asset reporting from 1 January 2026; first auto-exchange 30 September 2027.
• 50% expat exemption for new tax residents extended to 17 years for income > €55,000.

What to gather before a Cyprus Ltd filing. Timing depends on KYC completion, name approval, signatures and Registrar processing.

• Passport copy (certified) for each director + shareholder + UBO.
• Recent proof of address (utility bill / bank statement < 3 months old).
• Source-of-funds declaration with supporting docs (employment / business / inheritance).
• Proposed company name (1 preferred + 2 alternates for Registrar name-availability check).
• Memorandum & Articles preferences (single class shares? Multi-class? Special drag-along rights?).
• Registered office address (Nexora provides if no Cyprus location available).
• Bank-introduction preference (Cyprus traditional bank? Online EMI? Both?).
• VAT-registration intent (mandatory if turnover > €15,600/yr; otherwise voluntary).
• Beneficial ownership disclosure for UBO Register filing.
• Engagement letter signed digitally.

Everything you need on the personal side for Tax Residency + Non-Dom under the 60-day or 183-day rule.

• Passport copy (certified).
• Birth certificate (apostilled if foreign).
• Recent proof of address in Cyprus (lease agreement >12 months OR property purchase deed).
• Utility bill at Cyprus address in your name.
• Evidence of economic ties to Cyprus (Cyprus Ltd directorship / employment contract / business).
• Evidence of NOT being tax-resident in any other country (for 60-day rule).
• Day-count log demonstrating ≥60 Cyprus presence days.
• Source-of-funds documentation for any deposits during the residency year.
• Clean criminal record certificate (from country of previous residence).
• Marriage certificate + birth certificates of dependents (if extending to family).

The IP Box documentation file you must maintain annually for any successful IP Box claim. Defends against Tax Department audit.

• Qualifying-IP characterisation legal opinion (one-time, at structure setup).
• Per-project R&D ledger (timesheet allocations + costs + outputs).
• Annual Nexus Fraction calculation (qualifying expenditure / overall expenditure, with 30% uplift).
• Annual expense-attribution methodology (qualifying income vs non-qualifying).
• Worked qualifying-profit computation for the year.
• Supporting evidence: payroll records, contractor invoices, R&D contracts.
• Annual board minutes acknowledging IP Box claim.
• Annual IR4 corporate tax return with IP Box deduction claim.
• Audit working papers from ICPAC auditor.
• Optional: Advance Tax Ruling (ATR) for written Tax Department pre-clearance.

End-to-end completion sequence for a Cyprus share-sale M&A transaction. Post-2026, no stamp duty applies.

• Day 0 — engagement, NDA, indicative term sheet.
• Day 1-30 — due diligence: legal, tax, financial, commercial, regulatory. Cyprus Registrar + Tax Department file reviews.
• Day 30-60 — SPA negotiation, W&I insurance binding, regulatory clearances (CySEC / Competition Commission if thresholds met).
• Day 60-75 — Conditions Precedent satisfied: tax clearance certificate, share-transfer-form preparation.
• Day 75-90 — Completion: HE57 share transfer filed with Cyprus Registrar, consideration paid, board reconstituted, bank signatories updated.
• Post-completion — identify the company-law, tax and UBO updates triggered by the transaction. A reportable UBO change is generally filed within 45 days after awareness.
• 30-day SPA disclosure schedule warranties run.

What every Cyprus traditional bank + EMI expects in the KYC pack for non-resident-controlled corporate accounts.

• Certificate of Incorporation + Registrar certificate of Officers + Shareholders + Registered Office.
• Memorandum & Articles of Association.
• Latest HE32 annual return (if past Year 1).
• UBO Register filing extract.
• Director KYC: passport (notarised + apostilled), proof of address, CV / biography.
• Beneficial-owner KYC (same as director).
• Business plan: services offered, target markets, expected counterparties + transaction volumes.
• Source-of-funds documentation for initial deposit.
• Source-of-wealth narrative (audited accounts, employment evidence, sale-of-asset proof).
• Tax-residency self-certification + CRS / FATCA declaration.

The substance baseline that defends a Cyprus structure against CFC look-through + DTT Principal Purpose Test.

• Cyprus-resident director(s) — minimum 1, ideally 2; actively making management decisions.
• Quorum of board meetings physically in Cyprus — minimum 2-4 per year, minuted.
• Strategic decisions taken at Cyprus board meetings — major contracts, hiring, distributions.
• Bank account at a Cyprus bank used as primary operating account.
• Cyprus office (physical, not just a virtual address for higher-risk profiles).
• Cyprus phone line + Cyprus business email domain.
• Books and records kept in Cyprus — accounting records, contracts, board minutes, registers.
• Annual audited financial statements + IR4 filed by an ICPAC firm.
• Cyprus tax registrations: TIC, VAT/VIES, social insurance, employer's PAYE.
• At least one Cyprus-resident employee for higher-substance profiles.
• Documented operating-model alignment — company actually performs its declared activities.
• Insurance — D&O, professional indemnity, employer's liability where applicable.

Cyprus is the only EU member state with a 60-day tax-residency rule. Four ancillary conditions must all be met.

• Spend at least 60 days of the calendar year physically in Cyprus.
• NOT spend more than 183 days in any single other country.
• NOT be tax-resident in any other country.
• Carry out business / hold an office in Cyprus OR be employed in Cyprus.
• Maintain a permanent residence in Cyprus (owned or rented, >12-month lease).
• File the TD form declaring 60-day residency.
• File the IR.D form declaring non-dom status.
• Submit annual IR1 personal tax return.
• Maintain a contemporaneous day-count log.