Cyprus Corporate Structuring

Corporate Structuring for International Businesses

Two questions determine a corporate structure. Which entity type serves the commercial objective, and where more than one entity is required, how they should relate to each other. The answers follow from where the business operates, where its customers are, how revenue and profits move between jurisdictions, and what the shareholders intend over the longer term.

A structure is considerably easier to set well than to correct later. We advise on it first, then administer it.

Why Businesses Structure Through Cyprus

Corporate Tax at 15% Among the lowest in the EU. Tax reform discussions are ongoing for 2025 to 2026, though Cyprus remains committed to its competitive positioning.

65+ Double Tax Treaties Agreements with major economies across Europe, Asia, the Middle East and beyond. For holding structures and cross-border operations, this network is usually the deciding factor.

No Withholding Tax on Outbound Payments Dividends, interest and royalties to non-residents are generally exempt, subject to recent carve-outs for payments to blacklisted or low-tax jurisdictions.

IP Box Regime Qualifying income under the Cyprus IP Box regime benefits from an effective rate of 2.5%. For technology and content businesses, this alone can justify the jurisdiction.

English Common Law Foundation Contracts, corporate governance and dispute resolution follow a framework that international investors and counterparties already understand.

Full EU Market Access Passporting rights, regulatory recognition, and the credibility that comes with operating from a member state.

What We Advise On

Entity Selection Which vehicle serves the commercial objective, weighed against taxation, governance, administrative effort and cost.

Group and Holding Structures How several entities should relate to each other, where value should sit, and how profits move between them. Where a transaction is involved, we also advise on mergers and acquisitions.

Trusts and Asset Holding Where a trust is the more appropriate instrument, we advise on and establish Cyprus trusts alongside the corporate structure.

Substance and Governance Board composition, decision making, and the operational substance that must sit behind a structure for it to withstand scrutiny. Company administration and management is handled in house.

Shareholder Tax Position A structure rarely works in isolation from the individuals behind it. We advise on Cyprus non-domiciled tax residency where relocation forms part of the plan.

Ongoing Compliance Accounting and tax planning, handled by the same team that designed the structure.

Why Clients Work With Us

Single Point of Coordination Corporate advice, accounting, tax planning, legal counsel and banking and payment processing, managed by one team that understands how the pieces connect.

Long-Term Orientation We are not interested in transactional engagements. The businesses we advise today become the clients we advise for years, and our recommendations reflect that horizon. The people you meet are the people who do the work.

Cross-Border by Design Our processes assume international shareholders, distributed operations and multiple jurisdictions.

Digital and Technology Businesses

Most providers are comfortable with conventional trade and considerably less so once revenue moves through platforms, marketplaces and payment processors. That is where a large part of our work sits. Multi-market e-commerce, affiliate income, cross-border SaaS licensing, content and creator businesses, across the industries we serve.

A structure has to hold against the way the business actually earns. OSS and EU VAT compliance, platform terms, the location of intellectual property and the licensing arrangements between entities. Software and AI businesses in particular can reach an effective 2.5% rate on qualifying income. Where the business operates in a regulated sector, we also handle licensing for investment, crypto and payment businesses.

Next Steps

The appropriate structure depends on circumstances. Where the business operates, where its customers are, how revenue flows, and what the shareholders are building toward.

Arrange a conversation and we will set out what is involved, what it costs, and whether Cyprus is the right jurisdiction for the objective.