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Cyprus HoldCo · 0% WHT · 65+ DTT
0% withholding tax on outbound dividends (any country). Participation exemption on capital gains from share disposals (any holding, any country). 65+ double-tax treaties — including with most of the EU, the UK, Switzerland, UAE, Singapore. Setup from €1,499.
Request a free 30-minute initial consultation.
— WHAT YOU GET
Cyprus charges zero withholding tax on dividend distributions FROM a Cyprus Ltd TO any non-resident shareholder, regardless of country, holding percentage, or holding period. Combined with the EU Parent-Subsidiary Directive on inbound dividends (0% WHT from any EU OpCo to Cyprus HoldCo with 10%+ holding for 24 months), the structure is end-to-end zero-WHT clean.
Gains from qualifying securities can fall within the income-tax exemption. Cyprus immovable-property CGT rules, the seller's residence, transaction form, employment-linked value and foreign-country rules require separate review.
Treaty network covers all major commercial jurisdictions: UK (0% qualifying dividends), US (5–15%), Singapore (5%), UAE (0%), most of the EU. Many treaties offer 0% WHT on royalties + 0% WHT on interest, optimal for IP licensing structures.
Cyprus HoldCo with genuine substance (local director, board meetings, office address) is widely accepted by tax authorities globally as a non-conduit structure. We coordinate substance setup as part of the package — local director, board meetings, registered office in Cyprus.
— EVERYTHING INCLUDED
— PROCESS
Free 30-min: discuss your group (OpCos, IP, founder residence). We design the optimal Cyprus HoldCo flow — including any EU intermediate companies, branch structure, or fund-vehicle considerations.
Cyprus Ltd registration, director onboarding, share-class design and articles tailored to the proposed group. Timing is confirmed after the KYC and structure review.
Bank of Cyprus, Hellenic, Eurobank, or EMI (Revolut Business / Wise) — onboarding 4–8 weeks (Cyprus banks) or 5–10 days (EMI). We prepare the KYC pack and coordinate the bank interview.
Annual HE32, IR4 corporate tax return, audited financial statements, UBO register, board meetings minuted. Priced from our /pricing schedule based on transaction volume.
The Business tier can include a nominee-director service, registered office and local-bank introduction. These services do not by themselves establish tax substance or resolve CFC exposure; the facts and home-country rules must be reviewed.
— COMMON QUESTIONS
Compare the participation-exemption conditions, source-country withholding, defensive measures, treaty access, substance, governance and total compliance cost for the actual group. No jurisdiction is automatically preferable for every holding structure.
Yes. US-CY tax treaty (in force since 1985) gives 5% WHT on qualifying dividends US → Cyprus (LOB clauses apply). From Cyprus to US shareholder: 0% Cyprus WHT (US shareholder taxed under US worldwide rules). For US individuals, the Cyprus HoldCo provides a clean EU vehicle, but you remain subject to US worldwide taxation regardless of where the dividends originate.
If you're tax resident in a CFC-rule country (UK, Germany, France, US, etc.), your Cyprus HoldCo may be 'looked through' for tax purposes if it lacks genuine substance. We structure to ensure substance + economic activity — local director, board decisions in Cyprus, not a 'letterbox' company. With substance, most CFC rules don't apply.
The company filing, tax registrations, bank or EMI onboarding and any subsidiary transfers follow separate review processes. We map the dependencies and confirm an indicative schedule after KYC and structure review.
From our /pricing schedule: annual accounting is €800 + VAT for a nil-transaction dormant or holding company and starts at €2,100 + VAT/yr for an active company with up to 100 transactions, scaling by transaction volume. Annual Return HE32 is €200 and Professional Tax €150. Registered office + nominee secretary start at €349 + VAT/yr each. Nominee director starts at €799 + VAT/yr if used. We quote the exact bundle against your group structure in writing.
Send your enquiry for a no-obligation initial review.