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.
Free 30-min consultation. Reply within 24h.
— 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.
Cyprus exempts capital gains from share disposals from CGT entirely — regardless of holding period, percentage, or country of the subsidiary. Tax-free exit on every M&A. Unlike Netherlands or Luxembourg (which have nuanced participation-exemption rules), Cyprus's exemption is unconditional.
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 (5–10 working days), director onboarding (KYC pack), share class structure, articles tailored to your group needs (e.g., voting/non-voting, redeemable shares for VC tranches).
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.
Business tier ships with a Cyprus-resident nominee director, local Cyprus bank account, and registered office — a substance baseline that materially strengthens any CFC defence in your home country. If, within the first 12 months, we materially fall short of any item we promised in writing, we remediate at no cost.
— COMMON QUESTIONS
Three reasons: (1) Cost — Cyprus annual compliance is materially lower than Netherlands or Luxembourg equivalents (full Nexora pricing at /pricing). (2) Simpler participation exemption — unconditional in Cyprus, conditional in Netherlands (5% minimum holding) and Lux (12-month holding). (3) 0% WHT on outbound dividends to ANY country (Netherlands has 15% to some non-EU; Lux has 15% to most). Cyprus is structurally the cleanest.
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.
Cyprus Ltd registration: 5–10 working days. Bank account: 4–8 weeks (Cyprus banks) or 5–10 days (EMI). TIN + VAT registration: 2–3 weeks. Full operational setup including subsidiary transfers: 6–10 weeks typical. We project-manage the full sequence.
From our /pricing schedule: Annual Return HE32 €200 + Professional Tax €150 (statutory pass-throughs). Annual accounting from €800 + VAT/yr for a dormant / 0-transaction HoldCo (scales with transaction volume on the published bands). Registered office + nominee secretary from €349 + VAT/yr each. Nominee director €799 + VAT/yr if used. We quote the exact bundle against your group structure in writing.
Reply within 24 hours from a senior adviser. No obligation, no upfront fee.