Zypern Steuerreform 2026: Jede Änderung Erklärt

Überblick: Warum diese Reform wichtig ist

On 1 Januar 2026, Zypern implemented the most significant overhaul of its tax legislation since 2002. The reform package — comprising amendments to the Income Tax Law, Special Defence Contribution (Sonderverteidigungsabgabe) Law, and ancillary legislation — was driven by three converging pressures: the EU's mandatory implementation of Pillar Two (the Global Minimum Tax), the OECD's continuing pressure on preferential regimes, and Zypern's own strategic ambition to compete as a top-tier European holding and tech hub.

The changes are not minor tweaks. They represent a structural recalibration of how Zypern taxes businesses, investors, and individuals. Some provisions increase rates; others reduce them. The net effect — for well-structured businesses — is broadly neutral or positive, because the rate increases are offset by base erosions (Sonderverteidigungsabgabe reduction, DDD abolition, Stempelsteuer repeal) and new incentives (expanded Krypto framework, strengthened R&D deductions). Use our tax calculator to model the impact on your specific structure.

Körperschaftsteuer: 12,5% → 15%

The headline corporate income tax (Körperschaftsteuer) rate increased from 12.5% to 15%, effective for accounting periods beginning on or after 1 Januar 2026. This was required to satisfy the EU Minimum Tax Directive (Council Directive 2022/2523), which transposes Pillar Two into EU law. Zypern, like all EU member states, was obliged to implement a Qualified Domestic Minimum Top-Up Tax (QDMTT) to ensure that large multinational groups (consolidated revenue ≥ €750 million) pay a minimum effective rate of 15% on Zypern-source profits. See our full Zypern corporate tax guide for the complete picture on rates and deductions.

For businesses below the Pillar Two threshold — which is the vast majority of companies in Zypern — the Körperschaftsteuer increase applies as a straightforward rate change. A company with taxable profits of €500,000 will pay €75,000 in Körperschaftsteuer (up from €62,500 at 12.5%). However, the expansion of available deductions and the abolition of certain levies mean that effective tax rates for many businesses remain competitive.

Sonderverteidigungsabgabe auf Dividenden: 17% → 5%

Special Defence Contribution (Sonderverteidigungsabgabe) on dividends paid to Zypern tax-resident, Zypern-domiciled individuals has been reduced from 17% to 5%, effective 1 Januar 2026. This is a significant reduction in the personal tax burden on dividend income for domiciled shareholders.

Non-domiciled Zypern tax residents remain exempt from Sonderverteidigungsabgabe entirely — this position is unchanged. The non-dom status regime remains highly attractive for individuals who can establish Zypern tax residency and qualify for non-domicile classification.

Zypern tax-resident but non-domiciled individuals who hold shares in Zypern companies therefore continue to pay zero Sonderverteidigungsabgabe on dividends, while domiciled individuals now pay 5% (down from 17%). Combined with the absence of any EU-level dividend withholding tax (where the EU Parent-Subsidiary Directive applies), this makes Zypern one of the most dividend-efficient holding jurisdictions in Europe.

DDD (Angenommene Verteilungsdividende) Abgeschafft

The Deemed Distribution Dividend (DDD) rule required Zypern companies to distribute at least 70% of accounting profits within two years of the year-end, with any undistributed balance subject to Sonderverteidigungsabgabe at 17% as if it had been distributed. This was a persistent cash-flow and planning headache for founder-owned businesses that wished to retain earnings for reinvestment.

DDD is abolished for accounting profits arising from 2026 onwards. Profits accumulated prior to 2026 remain subject to the old DDD rules until distributed or until the two-year window expires — transitional planning is therefore important for companies with pre-2026 retained earnings. From 2026 forward, Zypern companies can accumulate profits indefinitely without any deemed distribution charge.

Stempelsteuer: Vollständig Abgeschafft

Zypern Stempelsteuer was fully abolished by Law 239(I)/2025, effective 1 Januar 2026. Previously, Stempelsteuer applied to a wide range of commercial documents at rates of €1.50 per €1,000 (up to €170,860) and €2.00 per €1,000 thereafter, capped at €20,000. Loan agreements, share purchase agreements, service contracts, and shareholders' agreements were all within scope.

The abolition removes a transaction cost that was particularly burdensome for high-value M&A, financing, and IP licensing transactions. It also simplifies document management — there is no longer any need to consider whether a document requires stamping before it can be produced as evidence in Zypern court proceedings.

Krypto & Digitale Vermögenswerte: Neuer Pauschalsatz von 8%

Article 20E of the Income Tax Law (as amended) introduces a dedicated 8% flat-rate tax on gains from the disposal of Krypto-assets and digital financial assets, effective for disposals on or after 1 Januar 2026. This applies to both individuals and companies, though the mechanics differ slightly. See our dedicated Kryptocurrency tax guide for a full breakdown.

For individuals, the 8% rate applies to net gains from Krypto disposals. Losses from Krypto activities are ring-fenced — they can offset other Krypto gains in the same tax year, but cannot be carried forward to future years and cannot offset gains from other asset classes (equities, property, etc.). This is a critical planning point for active Krypto traders.

For companies, Krypto gains are carved out of the normal Körperschaftsteuer base and taxed at the separate 8% rate. The same ring-fencing principle applies to company-level Krypto losses.

Defensive Quellensteuer auf Auslandszahlungen

New defensive withholding tax rules apply from 1 Januar 2026 to payments of interest, royalties, and dividends made by Zypern companies to connected parties in listed tax jurisdictions (LTJs) or EU-blacklisted jurisdictions (BLJs).

Payments to LTJs (jurisdictions with an effective tax rate below 7.5%): subject to 5% WHT. Payments to EU blacklisted jurisdictions: subject to 17% WHT. Additionally, such payments are no longer deductible as a business expense for Körperschaftsteuer purposes — a double penalty that significantly increases the effective cost of inter-group payments to non-cooperative jurisdictions.

The list of LTJs and BLJs is updated periodically by ministerial order. Advisers should verify the current lists before structuring inter-group flows.

F&E-Superabschreibung bis 2030 verlängert

The 120% R&D super-deduction — which allows companies to deduct 120% of qualifying research and development expenditure — has been extended to 31 December 2030. This deduction, available under the Innovation Box regime, is particularly valuable for tech companies and startups incurring significant software development, AI research, or product development costs.

Qualifying expenditure includes staff costs, subcontractor fees (with limitations), materials, and directly allocated overheads. The deduction can be combined with the IP Box regime where the R&D generates qualifying intangible assets.