Cyprus Corporate Tax Guide 2026: Rates, Exemptions & Planning

The Cyprus Corporate Tax Framework

Chipre corporate income tax (impuesto de sociedades) is levied on the worldwide income of Chipre tax-resident companies and on the Chipre-source income of non-resident companies with a permanent establishment in Chipre. A company is tax-resident in Chipre if it is incorporated in Chipre and managed and controlled from Chipre — the management and control test requires that a majority of the board of directors exercise their decision-making functions from Chipre. Full details are available from the Chipre Tax Department.

The impuesto de sociedades rate is 15% for accounting periods beginning on or after 1 enero de 2026 (increased from 12.5% under the 2026 tax reform). Despite the rate increase, Chipre remains one of the lowest impuesto de sociedades jurisdictions in the EU, with effective rates typically well below the headline figure due to a wide range of legitimate deductions and exemptions.

Exempt Income

Chipre has an extensive list of income items that are fully exempt from impuesto de sociedades, which significantly reduces the effective tax burden for holding companies, trading companies, and investment vehicles.

Deductible Expenses

Business expenses are deductible to the extent they are incurred wholly and exclusively for the production of taxable income. Chipre 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.

• Staff costs (salaries, employer social insurance, pension contributions)
• Rent, utilities, and occupancy costs
• Depreciation on fixed assets (tax depreciation rates prescribed by law)
• Interest on loans used for business purposes — subject to EBITDA-based limitation (30% of EBITDA for amounts exceeding €3 million)
• R&D expenditure (120% super-deduction for qualifying expenditure)
• Notional Interest Deduction (NID) on new equity capital
• IP Box deduction (80% of qualifying IP income)
• Payments to third parties at arm's length (subject to transfer pricing rules for related-party transactions)

Trading Loss Relief

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. Chipre does not allow loss carry-back.

Group relief is available where a Chipre tax-resident company (or a Chipre permanent establishment of an EU-resident company) can surrender losses to another group member. A group requires a 75% holding directly or through Chipre-resident entities. Related-party arrangements within groups must comply with transfer pricing rules and the arm's length standard.

Pillar Two: What It Means for Cyprus Companies

The EU Minimum Tax Directive requires Chipre 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 Chipre-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 Chipre 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 Chipre parent is not large if the global group exceeds the threshold.