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Cross-Border Groups · Holding Structures · 2026 Cyprus Tax

International Tax Advisory Cyprus

Senior-led Cyprus tax advice for international groups, founders and investors structuring ownership, operations, financing, intellectual property and cross-border transactions.

Holding CompaniesTreaty AnalysisWithholding TaxCFCTransfer PricingReorganisationsPillar Two
Commercial first, tax aligned

Cross-border structures that are
defensible in practice

International tax planning works only when the legal ownership, management, people, contracts, cash flows and transfer-pricing outcomes tell the same commercial story. We begin with the business model and the jurisdictions involved, then design or review the Cyprus position around that reality.

Cyprus’s standard corporate income tax rate increased to 15% from the 2026 tax year. The wider framework still requires careful analysis of exemptions, deductions, withholding taxes, anti-avoidance provisions, transfer pricing and international rules applicable to the particular group.

Tax reference: Cyprus Tax Department — Tax Reform 2026. Tax outcomes depend on the facts and law in force.

15%
Cyprus standard corporate income tax rate from 2026
Cross-border
Tax, TP and implementation coordinated together
International tax workstreams

From ownership structure to cash repatriation

Cyprus Holding Structures

Review or establish Cyprus holding companies around commercial substance, governance, tax residency, acquisition structures and expected dividend or disposal flows.

Treaty & Withholding Analysis

Analyse dividends, interest, royalties and service flows under Cyprus domestic rules and the relevant treaty or EU framework, including limitation and anti-abuse considerations.

Cross-Border Reorganisations

Tax analysis for share exchanges, mergers, asset transfers, group simplification, migrations and changes in ownership or functional profile.

International Financing

Coordinate tax treatment, interest deductibility, transfer pricing, guarantees, debt capacity and documentation for intra-group funding structures.

IP & Royalty Structures

Align ownership, DEMPE functions, licence agreements, royalty pricing and Cyprus IP Box analysis where software or qualifying intellectual property is involved.

CFC & Anti-Avoidance

Assess controlled foreign company rules, anti-hybrid considerations and wider anti-avoidance provisions relevant to the Cyprus entity and group.

Pillar Two Coordination

For in-scope large groups, coordinate the Cyprus workstream with global minimum-tax analysis, data requirements and group advisers.

Tax Rulings & Implementation

Where appropriate, support ruling requests, documentation, accounting treatment and practical implementation so the intended structure is reflected in actual operations.

High-value situations

When specialist international tax advice matters most

International Groups

Cyprus holding or operating entities within groups spanning multiple jurisdictions, financing arrangements and intercompany service flows.

Technology & iGaming

IP ownership, royalties, platform functions, payment flows, marketing entities, substance and transfer pricing across fast-growing digital businesses.

Founders & Private Capital

Ownership structures, relocation, investment holding, exits, acquisitions and succession planning requiring coordinated company and personal tax analysis.

Connected expertise

International tax rarely sits in isolation

Frequently asked questions

Practical questions, answered

What international tax work do you handle in Cyprus?

We advise on Cyprus holding and operating structures, cross-border reorganisations, withholding-tax analysis, tax residency, treaty positions, financing, intellectual property, transfer pricing and coordination of advice across jurisdictions.

What is the Cyprus corporate income tax rate from 2026?

From the 2026 tax year, the standard Cyprus corporate income tax rate is 15%. The effective tax result for a particular structure depends on the type and source of income, exemptions, deductions, anti-avoidance rules and the facts.

Can you advise on Cyprus holding companies?

Yes. We assess the commercial purpose, tax residency, substance, dividend and disposal treatment, financing, withholding-tax exposures, controlled foreign company rules and implementation requirements relevant to the wider group.

Do you coordinate advice with foreign tax advisers?

Yes. Cross-border structures should be analysed in every relevant jurisdiction. We can coordinate the Cyprus workstream with the client’s foreign legal and tax advisers or independent specialists.

Can tax and transfer pricing be handled together?

Yes. International tax and transfer pricing are often inseparable for intercompany services, financing, royalties and restructurings. We coordinate the legal agreements, functional analysis, pricing support and tax treatment where within scope.

Need a Cyprus tax position
that works internationally?

Share the group structure and transaction objective for a confidential initial review.

Confidential initial discussion
Technical insight: company tax residency in 2026
Why G. Adamides

Senior attention for complex Cyprus mandates

G. Adamides Audit Ltd is an independent ICPAC-regulated firm in Nicosia. Engagements are led by experienced professionals and coordinated across audit, tax, accounting, corporate, valuation and financial reporting disciplines.

Partner-led

Direct senior involvement from scoping through delivery, with clear accountability and communication.

International focus

Experience with international groups, founders, HNWIs, technology, iGaming, fintech and complex cross-border structures.

Coordinated delivery

Corporate documents, accounting records, tax analysis and audit evidence are aligned rather than handled in isolation.

Frequently asked questions

Practical questions, answered

What Cyprus tax services do you provide?

Services include corporate income tax, personal tax, transfer pricing, VAT, international structuring, reorganisations, tax residency, non-dom analysis, tax rulings and dispute support.

Can you coordinate advice across several jurisdictions?

Yes. G. Adamides works with independent legal and tax advisers in other jurisdictions so that Cyprus advice is implemented consistently with the wider structure.

Do you advise technology and crypto businesses?

Yes. The firm advises software, SaaS, fintech, crypto, iGaming and online-platform businesses on accounting, tax, IP ownership, revenue flows and compliance.

Is tax advice separate from statutory audit?

Where independence rules apply, the scope is assessed before accepting tax or advisory work for an audit client.

Confidential initial discussion