Tax Advisory & Planning

Is Cyprus still tax-competitive after the 2026 reform?

Yes. Even with the corporate rate at 15%, Cyprus remains one of the EU's most attractive jurisdictions because the reform left its core advantages intact. The participation exemption still removes tax on qualifying dividends and gains; the IP Box still delivers an effective rate as low as 3% on qualifying intellectual-property income; the Notional Interest Deduction still rewards equity funding; and there is still no withholding tax on most dividends, interest and royalties paid abroad.

Holding and group structures

Cyprus is a long-established holding jurisdiction. The participation exemption means qualifying dividends received from subsidiaries and gains on the disposal of shares are generally exempt from corporate tax, while the treaty network and EU directives reduce or eliminate withholding taxes on inbound flows. We structure holding, financing and trading companies so profits move through the group tax-efficiently and defensibly.

The key reliefs we plan around

Relief	What it does
Participation exemption	Exempts qualifying dividends and share-disposal gains from corporate tax
IP Box	80% deemed deduction on qualifying IP profit — effective rate as low as 3%
Notional Interest Deduction (NID)	Deemed deduction on new equity, rewarding equity over debt funding
Double tax treaties (65+)	Reduce withholding taxes on cross-border dividends, interest and royalties
Tax-loss carry-forward	Losses now carried forward seven years (was five)
R&D super-deduction	120% deduction on eligible R&D expenditure (in force to 2030)

Planning for individuals: non-dom and relocation

For founders, investors and high earners, the personal-side planning is just as valuable. Becoming Cyprus tax resident under the 60-day or 183-day rule, combined with non-domiciled status, can mean no Special Defence Contribution on dividends, interest or rents for up to 17 years. Qualifying new high earners can also exempt 50% of employment income. We coordinate the corporate and personal sides so the whole picture is optimised.

Turning the 2026 changes into savings

The reform created planning opportunities as well as a higher headline rate. SDC on dividends for domiciled residents fell to 5%; the deemed dividend distribution was abolished for post-2026 profits; losses now carry forward seven years; and new measures — an 8% flat rate on qualifying crypto gains, an 8% rate on qualifying employee share schemes, and tax-free ex-gratia payments up to €200,000 — open concrete routes to lower tax. We translate each change into a specific action for your situation.

Transaction and exit support

When you buy, restructure or sell, tax exposure can be made or lost in the structure. We provide tax due diligence, structuring for acquisitions and reorganisations, and exit planning, and we obtain advance tax rulings from the Tax Department where certainty matters.