Cyprus Corporate Tax Advisory
Tax Structuring Advisory
Bespoke tax structuring advisory for international founders relocating to Cyprus or establishing Cyprus corporate structures. We design structures that are efficient, compliant, and built to last.
What we advise on
End-to-end tax structuring services
Holding Company Design
Designing optimal Cyprus holding company structures to maximise the participation exemption on dividends, eliminate withholding taxes on distributions, and leverage Cyprus's 65+ tax treaty network for group income flows.
- Participation exemption analysis
- Treaty access and WHT minimisation
- Group cash repatriation planning
- Holding vs. trading company delineation
IP Box Planning
Structuring IP-owning entities to qualify for the Cyprus IP Box — achieving an effective ~3% tax rate on qualifying IP income. Nexus fraction analysis, qualifying expenditure mapping, and advance tax ruling preparation.
- IP Box eligibility assessment
- Nexus fraction calculation
- Qualifying asset identification
- Advance Tax Ruling preparation
Non-Dom Strategy
Advisory for founders relocating to Cyprus under the Non-Domicile regime — structuring personal income flows to eliminate SDC on dividends and minimise overall effective tax rates.
- Non-dom eligibility assessment
- 60-day residency rule planning
- SDC exemption structuring
- Salary vs. dividend optimisation
Exit & Disposal Planning
Structuring for tax-efficient exits — whether a business sale, secondary buyout, IPO, or investment disposal. Cyprus's broad securities exemption eliminates CGT on qualifying share disposals.
- Pre-exit restructuring
- Securities exemption analysis
- Step-up planning
- Cross-border exit considerations
Transfer Pricing
Arm's length structuring and documentation for intragroup transactions. Preparation of Local Files and compliance with the 2026 reform's updated thresholds — €5M for financing, €1M for other controlled transactions.
- Local File preparation
- Intercompany agreement drafting
- Benchmarking studies
- Summary Information Table (SIT)
Group Restructuring
Advising on restructuring existing multinational groups to incorporate a Cyprus holding or IP company — including tax-neutral migrations, share swaps, and mergers under the EU Merger Directive.
- Tax-neutral restructuring pathways
- EU Merger Directive analysis
- Regulatory and substance requirements
- Post-restructuring compliance setup
Why Cyprus
The Cyprus tax advantage
How It Works
From structure design to implementation
Discovery Call
We understand your current structure, business model, revenue streams, and objectives. No generic advice — every engagement starts with understanding your specific situation.
Structure Design
We design a bespoke Cyprus tax structure tailored to your circumstances, analysing holding layers, IP ownership, director tax residency, and substance requirements.
Implementation
We coordinate incorporation, UBO registration, nominee arrangements (if applicable), and all statutory filings. You receive a complete, operational structure.
Ongoing Advisory
Tax structuring is not a one-time event. We provide ongoing advisory as your business evolves, regulations change, and new planning opportunities arise.
Ready to structure your Cyprus business correctly?
Every situation is different. Book a strategy call to discuss your specific structure, or request a custom proposal.