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Cyprus Corporate Tax · International Planning

Tax Services

Strategic tax planning and meticulous compliance for Cyprus entities and international groups — minimising legitimate exposure while maintaining full regulatory compliance across every jurisdiction.

CIT ReturnsTransfer PricingDAC6International TaxTax PlanningTreaty NetworksBEPS
Our philosophy

Tax efficiency
done defensibly

Cyprus's tax framework is one of Europe's most attractive — but extracting maximum legitimate benefit requires precise structuring, meticulous documentation, and deep knowledge of both domestic law and the international treaties Cyprus has concluded. We deliver all three.

Our approach is to understand the commercial reality of your business first, then engineer a tax-efficient structure around it — not to reverse-engineer a structure that might unravel under scrutiny. Every planning position we take is defensible on audit.

15%
Cyprus standard corporate income tax rate — one of the EU's lowest
65+
Double tax treaties providing cross-border planning flexibility
Service areas

Comprehensive tax coverage

Corporate Income Tax (CIT)

Preparation and submission of IR4 corporate tax returns, provisional tax calculations, tax computations, and liaising with the Cyprus Tax Department on assessments and queries.

Transfer Pricing

TP documentation for intra-group transactions, benchmarking studies, and Advance Pricing Agreements. Full compliance with OECD guidelines and Cyprus TP regulations effective 2022.

DAC6 Reporting

Identification of reportable cross-border arrangements, preparation of DAC6 disclosures, and filing with the Cyprus Tax Department. We review existing structures for retroactive disclosure obligations.

International Tax Planning

Treaty-based structuring, withholding tax optimisation, holding company analysis, and thin capitalisation advice for groups operating across multiple jurisdictions.

Personal income tax returns for Cyprus-resident HNWIs, non-domicile planning, Special Defence Contribution and GHS/GeSy considerations and personal tax residency advice for relocating individuals.

Tax Dispute Resolution

Representation before the Cyprus Tax Department in the event of assessments, objections, or penalty disputes. We protect your position robustly and professionally.

Case studies

Selected anonymised engagement examples are provided for context only. Outcomes depend on each client’s facts, evidence, implementation, third-party decisions and the law in force; similar results are not guaranteed.

Representative engagements

European E-commerce Group · Transfer Pricing
TP documentation for intra-group management fees between Cyprus holding and EU operating subsidiaries

A European e-commerce group with Cyprus holding company paying management fees to subsidiaries in Germany and Romania faced a Tax Department enquiry challenging the arm's-length nature of the fees. Existing documentation was inadequate to withstand scrutiny.

Outcome
Comprehensive TP study prepared with OECD-compliant benchmarking
Tax Department enquiry successfully closed with no adjustment
Annual TP documentation retained as ongoing compliance deliverable
DAC6 review conducted — two historical arrangements disclosed retroactively
HNWI Relocation · Non-Dom Planning
Comprehensive Cyprus tax residency and non-domicile planning for relocating UHNWI

A Ukrainian HNWI relocating to Cyprus with a portfolio of international investments, a yacht, and property in three jurisdictions required a coordinated approach to establishing Cyprus tax residency, non-dom status, and optimising their overall international tax position.

Outcome
Cyprus tax residency established under the 60-day rule
Non-domicile status confirmed — qualifying passive income may be exempt from Special Defence Contribution under the non-dom rules; GHS/GeSY is considered separately
Investment holding structure redesigned for optimal withholding treatment
Material estimated annual tax efficiencies identified across the combined structure, subject to implementation and ongoing compliance
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