Corporate Structuring
International Tax Planning
Cross-border structuring against ATAD, Pillar Two and treaty tie-breaker rules.
What we do
We design the Cyprus part of a cross-border group and make sure it fits with everything around it. What each entity does, where its decisions are taken, how income moves between them, and which reliefs the structure actually depends on.
A structure can no longer be optimised jurisdiction by jurisdiction. A position that is efficient here and triggers a controlled foreign company charge where the founder lives has saved nothing, and a rate advantage stops mattering the moment a group crosses the Pillar Two threshold. So the work is to build a Cyprus position that still reads well from every other capital that will look at it.
What you get
- The group mapped as it actually operates: entities, ownership, flows, functions, and where decisions are really taken
- The Cyprus position designed and advised on, in writing, in a form your advisers elsewhere can work from
- Treaty and directive analysis on dividends, interest and royalties moving in and out of Cyprus
- A Pillar Two threshold review, and top-up exposure modelled where the group is near it
- ATAD review of the Cyprus entities: interest limitation, hybrid mismatches, exit taxation
- The substance each Cyprus entity needs to support what is being claimed through it
- The specific questions your advisers in the other jurisdictions need to answer, written out rather than described
- Reorganisation planning where the structure you have cannot carry the position you want
- Tax residency and tax clearance certificates, and ruling applications where a position warrants certainty
How it works
We map before we advise. The first thing produced is a picture of the group as it operates rather than as the chart draws it: where the people are, where the contracts are signed, where the pricing is set. Almost every structure that fails does so in the gap between those two pictures.
Then the claims are identified. The founder's country of residence, the parent's jurisdiction and sometimes the customers' all have a view, and the Cyprus analysis does not settle any of them. We advise on the Cyprus side and set out precisely what your advisers elsewhere need to confirm. That division is deliberate: we are licensed in Cyprus, and an opinion from us on another country's law would be worth nothing to you.
Where a group is approaching the Pillar Two threshold, most rate planning below 15 percent stops being useful, so establishing whether the threshold is in view changes which options are worth discussing at all. And where an intended outcome is not available without more relocation or substance than you want to commit to, we say so at the start. That conversation is cheaper before a structure is built than after.
Working with us
Four steps, and the first one is a conversation
A call
What the group looks like now, where the people are, and what you are trying to achieve. No charge for it.
A proposal in writing
Fixed fees, not estimates, for the analysis, with implementation costed separately so you can decide on each.
You accept
Engagement letter signed, then onboarding. Neither takes long.
You have a position you can act on
The Cyprus analysis in writing, the questions for your other advisers listed, and a route from the structure you have to the one that works.
Common questions
Cyprus is 15 percent now. Is it still worth it?
For most of our clients the rate was never the main reason. The participation exemption on incoming dividends, no withholding on distributions out, gains on securities outside the corporate charge, the intellectual property regime at roughly 3 percent at full nexus, and full EU and treaty access do more work than the headline rate ever did. Fifteen percent also puts Cyprus at the Pillar Two floor rather than below it, which removes a problem rather than creating one.
Will my home country tax the Cyprus company anyway?
It depends on their controlled foreign company rules and on where the company is genuinely managed, which is why substance and the founder's own residence are part of the same question. We build the Cyprus side to withstand that examination and tell you exactly what to put to an adviser at home.
Does Pillar Two apply to us?
Only above the consolidated revenue threshold, which most privately held groups are nowhere near. Checking is quick and it is worth doing early, because for a group that is close, it changes which options are worth considering at all.
Can you work with our existing advisers?
Routinely, and it is the arrangement that produces the best result. We hold the Cyprus position and they hold theirs, and the coordination between the two is part of what we do rather than something left to you to manage.
What follows
Analysis is worth what its implementation is. Formation or redomiciliation puts the entities in place, substance makes them hold, and transfer pricing documents what moves between them.
The structure is then reviewed each year alongside the accounts, because groups change faster than the rules they were designed against.
| Cyprus corporate rate | 15 percent from 1 January 2026 |
|---|---|
| Pillar Two | A 15 percent global minimum for groups above the consolidated revenue threshold |
| ATAD | Interest limitation, exit taxation, CFC rules and anti-hybrid provisions |
| Treaty position | Cyprus maintains an extensive double tax treaty network |
| Directive relief | Parent-Subsidiary and Interest and Royalties Directives |
| Governing constraint | Substance in each jurisdiction where a benefit is claimed |
Also in Corporate Structuring
- Cyprus Company FormationExpedited incorporation with every mandatory registration, and the Registrar and government fees included in one fee.
- Cyprus Holding CompanyHolding structures using the participation exemption and Cyprus treaty network.
- Company RedomiciliationTransfer of an existing foreign company into Cyprus without breaking legal continuity.
- Economic SubstanceManagement and control, governance and the evidence file that supports tax residency.
Find out whether Cyprus fits your plans
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.