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Reach a defensible answer for a specific situation.
For a Cyprus company, foreign dividends are exempt in most cases under the participation exemption, and are charged only where the payer is predominantly passive and taxed below 7.5 percent. For an individual, the answer turns on domicile rather than on the source of the dividend.
There is no single answer, because the deciding variable is where the engineering is funded rather than which rate is lowest. Cyprus, Ireland, Estonia and the Netherlands each win under different conditions, and the choice should follow the team and the customers.
Not directly. The deduction is available to a company that is tax resident in Cyprus, which turns on management and control rather than on incorporation. Reaching it means bringing the company to Cyprus by redomiciliation, or bringing the asset to a Cyprus company.
There is no legal requirement for a Cyprus company's directors to be resident in Cyprus. But corporate tax residency follows incorporation in Cyprus or management and control exercised in Cyprus, and where another country also claims the company it is management and control that decides. A board that meets and decides abroad is the clearest way to fail that test.
Not on the same asset. Cyprus grants an additional 20 percent deduction on development spending for the years 2025 to 2030, giving 120 percent. It is not available for expenditure on a qualifying intangible asset where the IP Box has been applied in any year, including the current one.
Only on their own facts. Domicile is personal and is not shared between spouses, so each individual is assessed separately on their domicile of origin and their own residence history. One spouse can be non-domiciled while the other is deemed domiciled.
Regulation 6(2) grants permanent residence on a qualifying investment of 300,000 euro plus VAT, supported by secured annual income from abroad of at least 50,000 euro. The permit does not expire, and it does not make the holder Cyprus tax resident.
A residence permit gives permission to live in Cyprus. Tax residency decides which country taxes you. They are granted by different authorities under different tests, and the permit that lets you stay can be the one that blocks the 60-day route to tax residency.
A model can qualify where it rests on a legally protected asset, most often copyright in the training and inference code, and where the company funded the development. Trained weights alone sit on weaker ground than the code that produces them, so the claim is usually built around the system rather than the model file.
We treat a founder's salary as a related party cost and outside qualifying expenditure. The Regulations admit wages and salaries but exclude amounts paid to a connected person for carrying out research and development, and a founder who owns the company and writes the code is both.
Yes. Copyrighted software is a qualifying intangible asset, so a Cyprus company licensing or embedding its own software can claim the 80 percent deduction. Whether meaningful benefit follows depends on the nexus fraction, which measures how much of the development the company funded itself rather than acquiring from a related party.
Yes, and in two separate ways. The company must be Cyprus tax resident on the management and control test, and the nexus fraction independently requires that the company funded the development itself. Satisfying one does not satisfy the other.
Until you have been Cyprus tax resident for 17 of the previous 20 tax years, at which point you are deemed Cyprus domiciled and Special Defence Contribution begins to apply. From 1 January 2026 a person with a foreign domicile of origin may extend the status by up to two further five-year periods for a lump sum.
There is no statutory number. Cyprus applies a management and control test rather than a headcount test, so what is required scales with the activity, the value carried and the relief being claimed. A passive holding company and an operating software business are not asked for the same thing.
Start by confirming the licence, because providing company administration and directorships in Cyprus is a regulated activity. After that the questions that separate providers are who signs, what happens when they disagree with you, and what the fee actually includes.
A nominee director sits on the board and owes duties to the company. A power of attorney authorises someone to act on your behalf and creates no board seat. They solve different problems, and using a power of attorney to run a company from abroad undermines the management and control position.
Selling the shares of a Cyprus company produces no Cyprus tax on the gain, subject to the property test. On an asset sale, intellectual property disposed of as a capital asset is generally exempt, while a disposal forming part of the company's recurring trade is charged to corporate tax at 15 percent.
Timing decides the outcome. Cyprus exempts gains on the disposal of securities and charges no Special Defence Contribution on dividends for a non-domiciled resident. Both depend on residency being established before the disposal, and on the departure jurisdiction not retaining a claim.
Yes, and for most software groups it is the preferred structure. A Cyprus IP holding company owns the code and licenses it to an operating company for a royalty. The nexus fraction is maintained by having the IP company itself fund the development, through its own staff or unrelated contractors.
The costs are real: an annual assurance engagement, a bank relationship measured in weeks, and substance that has to be genuine. They are comfortably outweighed where a business moves something real, and wasted where it moves only a registration. Deciding which one you are is the whole exercise.
The company that funds the development should own the code. Ownership split from funding produces a weak nexus fraction, a transfer pricing problem and an assignment gap at diligence. Deciding this before the spending starts is worth more than any restructuring afterwards.
A Cyprus holding company receives most foreign dividends free of Cyprus tax under the participation exemption, pays no withholding tax on dividends out to non-residents, and is exempt on gains from disposing of shares. The combination makes it efficient at holding subsidiaries and at receiving a sale price.
Incorporation is the cheapest part of a Cyprus structure and the least consequential. A licensed provider supplies the registered office, resident directors, statutory records and filings that the residency position depends on, and several of those services may only be provided under a licence.
It starts with three questions: where your revenue comes from, what you own, and where you are tax resident. From there, the conversation is about what you are building and where you want to take it. After the call, you receive a written proposal covering the recommended structure, the implementation roadmap, and a fixed fee quote.
