Overview

Cross-border structuring is now constrained from several directions at once. ATAD imposes interest limitation, exit taxation, controlled foreign company rules and anti-hybrid provisions across the EU. Pillar Two applies a 15 percent floor to groups above the consolidated revenue threshold regardless of where profit is booked. Treaty access depends on substance, and the treaties themselves carry anti-abuse provisions.

The practical effect is that a structure can no longer be optimised jurisdiction by jurisdiction. A position that is efficient in Cyprus and creates a controlled foreign company charge in the founder's home country has not saved anything, and a rate advantage below the Pillar Two threshold disappears once a group crosses it.

The work is therefore to establish a position that holds when all the relevant authorities look at it, and to say plainly where a client's intended outcome is not available.

What is included

Mapping the group as it stands: entities, ownership, flows, functions and where decisions are taken
Controlled foreign company analysis in each jurisdiction with a claim over the group
Treaty analysis, including tie-breaker exposure for both companies and individuals
Directive relief assessment on cross-border dividends, interest and royalties
Pillar Two threshold review and, where relevant, top-up exposure modelling
ATAD review covering interest limitation, hybrid mismatches and exit taxation
Substance requirements in each jurisdiction where a benefit is claimed
Reorganisation planning where the existing structure cannot support the intended position
Coordination with counsel and advisers in the other jurisdictions involved

How Doviandi approaches this

We map before we advise. The first deliverable is a picture of the group as it actually operates, including where people are, where contracts are signed and where decisions are made. Structures fail on the gap between that picture and the one on the chart.

Every jurisdiction with a claim is considered. A Cyprus position is only useful if the founder's country of residence, the customers' jurisdictions and the parent's jurisdiction all reach compatible conclusions. We identify the competing claims rather than assuming the Cyprus analysis settles them.

Pillar Two is checked early. For groups approaching the consolidated revenue threshold, most rate planning below 15 percent stops being useful. Establishing whether the threshold is in view changes which options are worth discussing at all.

Where the answer is no, we say so. Some intended outcomes are not available without a level of relocation or substance the client is unwilling to accept. Identifying that at the outset is cheaper than implementing a structure that will be unwound.

Background reading on the questions this service answers:

Cyprus or Dubai on how EU access, substance and Pillar Two change a comparison usually made on headline rate alone.
Best EU country for a SaaS company on why the location of funded development decides more than the corporate rate does.
Economic Substance on the management and control test every Cyprus element of a cross-border structure depends on.

Engagement at a glance
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