Double Tax Treaties
With the entrance of Cyprus into the European Union and the enactment of new company legislation in 2003, Cyprus has developed into one of the most appealing holding jurisdictions worldwide. As a country, Cyprus has successfully linked its global network with over 40 double income taxation treaties (2006), with an outstanding holding regime.
Cyprus Legislation Requirements
- Full participation exception for resident companies for divided income received from subsidiary companies
- Application for EU Parent / Subsidiary Directive (providing a qualifies tax exemption for the inter – EU cross-border distribution.
- Freedom to distribute dividends, interest and royalties tax fee from Cyprus to any Country.
- No minimum holding period for shares prior to liquidation.
- No controlled foreign corporation ( CFC) legislation.
- No substance requirements for Cyprus Holding Company or underlying subsidiaries.
- Full tax exemption on the receipt of capital gains from the disposal of shares into a subsidiary.
- Freedom to distribute capital gains tax from the disposal (or liquidation) of the shares of the Cyprus holding Company tax free to any country.
- No capital taxation to capitalise Cyprus Companies.
- Net worth taxes during the life of a Cyprus Company.
CYPRUS Double Tax Treaties
• Austria • Bulgaria • Belarus • Belgium • Canada • China • Denmark • Egypt • France • Germany • Greece • Hungary • India • Ireland • Italy • Kuwait • Lebanon • Malta • Russia • Norway • Poland • Romania • Mauritius • South Africa • Sweden • Syria • Singapore • Thailand • United Kingdom • USA • Serbia • Montenegro • Slovenia • Slovakia • Czech Republic • Azerbaijan • Armenia • Kyrgyzstan • Moldova • Ajikistan • Uzbekistan • Ukraine • Seychelles • San Marino • Qatar • United Arab Emirates • Estonia • Finland • Portugal • Spain