Your Situation
US-controlled foreign corporations face GILTI inclusion on most active profits. A Cyprus company with genuine substance, IP Box treatment and the right shareholder structure can reduce the GILTI sting via the high-tax exclusion, which Cyprus's headline 15% can satisfy.
Without planning, a Cyprus company held by US shareholders can produce ugly Subpart F or PFIC outcomes. The right Cyprus structure (operating company, real R&D, no passive-investment income) keeps the entity firmly outside Subpart F categories.
Cyprus-resident or Cyprus-formed companies owned by US persons trigger Form 5471 reporting. We coordinate with your US CPA to align the Cyprus IR4 reporting and Cyprus financial statements with the Schedule M and E disclosure requirements.
The US–Cyprus tax treaty provides foreign-tax-credit relief on Cyprus tax paid, reducing the US worldwide-tax bite. Cyprus is one of the most US-treaty-friendly EU jurisdictions for software / IP businesses.
What Cyprus Offers You
Relocation Timeline
GILTI / Subpart F / PFIC analysis with your US CPA, decide whether Cyprus entity is checked-the-box C-corp or default classification, draft Form 8832 / 5471 working papers.
Cyprus Ltd incorporated, Cyprus director appointed, lease signed, EMI account opened. Real R&D contract path defined for IP Box.
ATR submission to Cyprus Tax Department locking in the regime's application to your specific facts. Government fee €1,000 (€2,000 expedited).
Cyprus IR4 + audited financial statements aligned with Form 5471 disclosure, GILTI inclusion calculation, and your US 1040.
Frequently Asked Questions
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Legal Disclaimer: This page is for general informational purposes only and does not constitute legal or tax advice. Tax laws change frequently. Always seek independent professional advice tailored to your specific circumstances before making relocation or tax planning decisions.