Cyprus
International Tax &
Business Environment
Foreword
I am pleased to introduce our guide to the international tax and business
environment in Cyprus.
Cyprus is well placed literally and metaphorically as the gateway between
Europe and the rest of the world. The geographic location of Cyprus at the
eastern-most point of Europe, bordering three continents, as well as the
Cypriot tax and business environment make Cyprus the ultimate country
for investors and businesses moving into Europe and for European business
expanding internationally. Cyprus offers many key bene?ts that contribute to
the success of business and investments and Deloitte in Cyprus is well placed
to ensure this success.
Deloitte is known for its values of ethos, integrity, specialized knowledge and
professionalism. Our ongoing commitment to continuous investment in our
people and our deliverables is the key to our success and our ability to look
at business issues from every angle is what sets us apart.
Deloitte in Cyprus can coordinate with the Deloitte member ?rms around
the world and other advisers to assist entrepreneurs and groups investing
and operating through companies incorporated and tax resident in Cyprus.
In addition to intermediary holding and ?nance companies, our Tax Services
team can assist with establishing Cypriot companies to perform other
functions which can bene?t from the favorable tax system and business
environment in Cyprus, such as ?nancial companies, investment trading
companies, intellectual property holding companies, shipping companies
and companies for oil & gas exploration as well as Cypriot fund management
companies and collective investment funds.
Deloitte in Cyprus has the ability to offer practical solutions that are
adapted to the needs of all businesses. Whether considering establishment
in new markets, acquisitions or rationalization of current operations, our
professionals can assist in the planning and implementation. Deloitte in
Cyprus will ensure that investors and businesses will achieve signi?cant
bene?ts in these cross-border transactions and investments.
We at Deloitte Cyprus look forward to working with you.
Christis M. Christoforou
Chief Executive Of?cer
Contents
2-3 The Cyprus business environment
4-5 The Cyprus tax system
6-7 The formation & uses of Cyprus companies
8 Cyprus investment funds
9 Cyprus international trusts
10 Cyprus shipping
11-12 Our services
Contacts
Cyprus - International Tax & Business Environment 1
2
The Cyprus business
environment
Reputation and stability
Cyprus joined the European Union in 2004, resulting in
an economy offering a great number of advantages
within a common European market. The Euro was
adopted by Cyprus as its unit of currency on 1 January
2008, further con?rming the country’s macro-economic
stability and its commitment to low in?ation, low
interest rates and high growth.
Cyprus participates in the European Union’s internal
market where there is free movement of goods, services
and capital. European citizens are able to conduct
business, travel to, and live in Cyprus with no legal
restrictions.
Demonstrating a stable ?nancial and business-friendly
environment since the 1970s, Cyprus has attracted
foreign investment and capital ?ows for decades. The
country’s ?nancial and regulatory environment is
harmonized with that of the European Union and the
Cyprus tax system is aligned with European principles of
equality within the framework of the European Union
Code of Conduct for business taxation and
demonstrates a commitment by Cyprus to the OECD
against harmful tax practices.
In April 2009 the OECD included Cyprus on its original
white list as one of only 40 countries in the world that
have substantially implemented internationally agreed
tax standards, being the highest categorization possible.
Being on this OECD white list supports Cyprus’s position
as a sound and reputable environment from which
international business operates.
Strategic location
The island of Cyprus is situated in the eastern
Mediterranean at the hub of three continents, linking
Europe with the Middle East, Africa and Asia.
Cyprus is one hour by air from Athens, Egypt and Israel,
three hours from Dubai and Moscow and four hours
from London.
Cyprus is two hours ahead of Greenwich Mean Time
(GMT).
International familiarity
Banking & ?nancial regulation
Commercial banking follows the British and European
Union models and is of a very high standard. There are
currently over 40 Cypriot and international banks
operating in Cyprus.
The banking system conforms to EC Directives, under
the regulation of the constitutionally independent
Central Bank of Cyprus, as integrated with the
Eurosystem. The Bank’s governance is compatible with
the provisions of the Treaty establishing the European
Community and the Statute of the European System of
Central Banks and of the European Central Bank.
The Cyprus Securities and Exchange Commission (CySEC)
supervises and controls the operation of the Cyprus
Stock Exchange and the issuers of securities listed on the
Exchange.
The Central Bank and CySEC supervise and licence the
growing number of investment services companies,
collective investment schemes, brokerage ?rms,
investment consultants and mutual fund management
companies.
In recent years Cyprus has been voted
the most attractive European tax
regime by major business organisations
across Europe. Cyprus has been
commended for the stability of its tax
law, the consistency in interpreting its
tax legislation and its low tax rates.
This accolade shows how the Cyprus
tax system, combined with its frst-rate
infrastructure, highly skilled workforce
and membership of the European
Union has made Cyprus the
international business hub it is today.
Cyprus - International Tax & Business Environment 3
Legal system
Cyprus has a well-functioning common law legal system
based on principles established through historical links
with the United Kingdom.
The origin of Cyprus company law and other laws
regulating business is the laws of the UK, updated for
21
st
century business practice and harmonised with EC
Directives.
The familiarity of the legal and commercial systems
assists international business people in working within
the Cypriot commercial environment. English is spoken
universally and is the accepted language of business.
Political respectability
Cyprus has excellent diplomatic and economic relations
with the rest of Europe as well as, China, Russia, India,
North America and the countries of the Middle East.
As a result, Cypriot entities enjoy great respectability
around the world.
Telecommunications
Cyprus has a highly advanced telecommunications
infrastructure system with a number of companies
providing modern telecommunication products and
solutions.
Air transport
The two international airports in Cyprus are served by
over 35 international airlines. There are daily ?ights to
other European countries, Russia and the Middle East
including major hubs for onward and long haul
international destinations. New airport terminals at both
Larnaca and Pafos international airports can serve up to
10 million passengers per annum.
Economy
Cyprus has an open-market economy with the private
sector comprising the backbone of economic activity.
Private enterprise is greatly promoted and supported by
decades of consistent government policy.
Cyprus ranks amongst the top half of EU countries in
terms of GDP per capita (currently €20,700 per annum).
In recent years up to 2009 the economy grew at an
average rate of 4% in real terms and the unemployment
rate is in the region of 5% of the labour force. In
addition, in?ation has been relatively modest with
increases in the consumer price index in the region of
2.5% per annum in recent years.
High standard of living – low cost base centre
and skilled workforce
Economic indicators place Cyprus amongst the few
international ?nancial centres with low operational
costs. At the same time, the island offers a high
standard of living with an enjoyable climate and a very
low crime rate making it an ideal place to live and
conduct business.
The costs of setting-up and maintaining a structure in
Cyprus are low when it comes to incorporation costs
and fees for meeting Cypriot tax and company law
compliance obligations.
The cost of labour, rents and other infrastructure are
highly competitive and often lower than in other
European countries.
Cyprus has a young and ?exible work force, with
university education obtained predominantly in the UK
and the USA. The island ranks among the leading
countries in the world and the highest in the European
Union in respect of university graduates in proportion to
its population, with the percentage of graduates from
tertiary institutions being the highest in the EU.
4
The Cyprus tax system
Cyprus’s advantageous tax system
Cyprus has all the tax attributes expected from an
international ?nancial centre
The Cyprus tax legislation and its regulation is
predictable and straight forward in nature. Relations
between the business community and the tax authorities
are excellent and ensure the ef?cient taxation of the
commercial and ?nancial sector. By providing a
transparent and ef?cient environment, the tax system
enhances Cyprus’s competitiveness and contributes to
making Cyprus an attractive jurisdiction in which to
structure international operations.
Corporate tax rate
Cyprus has a corporate income tax rate of 12.5%. This is
the lowest corporate tax rate in the European Union.
Exemption from tax on dividend income
Dividend income is exempt from tax irrespective of its
source provided that the company paying the dividend
either engages directly or indirectly in more than 50% of
activities that give rise to non-investment income or the
tax burden on the dividend paying company’s income is
not lower than 6.25%.
Dividends are not considered to be sourced from
investment income if they are derived directly or
indirectly from trading subsidiaries.
No withholding taxes
Dividends paid to non-resident shareholders are exempt
from withholding tax in Cyprus. Also, no withholding
tax is imposed on interest paid from Cyprus as well as
on royalties paid from Cyprus in respect of intellectual
property exploited outside Cyprus. The nil withholding
tax rates apply irrespective of whether the recipient is a
body corporate or an individual, the country of
residence of the recipient or whether a relevant tax
treaty exists.
Capital gains and income tax exemption for
securities
Cyprus does not impose income or capital gains tax on
the pro?ts and gains derived from the disposal of
securities, irrespective of whether the pro?ts and gains
are considered to be of a revenue or capital nature.
Securities, as de?ned in the law, include shares, bonds,
debentures, founder’s shares and other securities of
companies or other legal persons and options over such
securities.
Capital gains and income tax exemption for real estate
Cypriot companies can be used to hold real estate or
other assets outside Cyprus with no Cypriot capital gains
tax implications on disposal of the assets as capital gains
tax only applies to gains on the disposal of immovable
property which is situated in Cyprus or unlisted shares in
a company which owns immovable property situated in
Cyprus.
Permanent establishment abroad
Pro?ts from a permanent establishment maintained
abroad are generally exempt from tax in Cyprus.
Income from intellectual property
Only 20% of the net pro?ts derived by a Cyprus
company from the exploitation of its intellectual property
is subject to tax at the normal corporate income tax rate
of 12.5%. The net pro?t is calculated after deduction of
all costs incurred in earning the income, including 20%
of the cost of the intellectual property in each of the ?rst
?ve years of ownership.
Interest deductibility
Interest incurred by a Cypriot company is generally
deductible if incurred in respect of funding the
acquisition of assets used in a business which derives
taxable income. Practice statements and case law
provide further guidance on deductibility of interest.
Thin capitalisation
Cyprus does not have any thin capitalization rules or
minimum capitalization requirements.
A wide network of tax treaties
Cyprus boasts an extensive network of tax treaties,
currently with more than 50 countries, including
countries in North America, Western and Eastern Europe
Cyprus has become a favored location
for international commerce as well as
for reputable multinationals seeking a
legitimate tax effcient jurisdiction –
raising Cyprus to a new level of
international business.
Cyprus - International Tax & Business Environment 5
as well as emerging markets such as China, India and
Russia.
Generally, most treaties provide for reduced or nil rates of
withholding tax on dividends, interest and royalties paid
from the treaty country and the avoidance of double
taxation in the case where a resident in one of the treaty
countries derives income from the other treaty country.
Unilateral tax credit relief
Relief for taxes paid abroad is in the form of a tax credit
if the respective income is subject to tax in Cyprus. The
relief is given unilaterally irrespective of the existence of
a double tax treaty. Where a treaty is in force, the treaty
provisions apply if more bene?cial. Where dividend
income is received from a company resident in the
European Union or if a tax treaty provides, an underlying
tax credit is also allowed to the Cypriot recipient of the
dividend against any tax payable on that income.
Advance rulings and prior approvals
The Cyprus tax authorities provide advance
interpretations of the law under a ruling system.
VAT
The headline Cypriot VAT rate is 18% (19% from 13
January 2014). Reduced VAT rates of 5% and 8% (9%
from January 2014) apply to some goods and services.
Capital & net worth taxes, capital & stamp duties
Cyprus does not have any annual capital taxes and net
worth taxes and there are no signi?cant capital and
stamp duties.
Reorganizations
Cyprus has fully adopted the EC Merger Directive and
therefore where a transaction is a “reorganization”, it is
exempt from corporate income tax, capital gains tax,
stamp duties and property transfer fees.
A reorganization generally includes a merger, division,
part-division, transfer of assets and exchange of shares
involving companies which are resident in Cyprus and/or
companies which are not resident in Cyprus.
Cross border mergers and re-domiciliation of
companies
Cyprus legislation allows for the merger of two or more EU
member companies, whether a merger of Cypriot or Cypriot
and non-Cypriot EU member companies and whether the
Cypriot company is the surviving company or not.
Non-Cypriot companies which are allowed by their
jurisdiction of incorporation to deregister in that
jurisdiction and register elsewhere are able to become
domiciled in Cyprus. Cypriot companies are also permitted
to deregister from the Cypriot Register of Companies and
become domiciled in another jurisdiction.
Cross-border and domestic mergers, as well as the
redomiciliation and change in jurisdiction of tax residency
are generally tax neutral, there being no Cypriot “exit
taxation” applied to such restructures.
Liquidation of a Cypriot company
No capital gains tax, income tax or any other taxes arise
on the liquidation of a Cypriot company owned by
nonresident shareholders, irrespective of the method of
liquidation.
Personal tax
Personal tax rates
The personal tax rates are progressive and reach a top
marginal tax rate of 35% on income in excess of
€60,000 per annum. An individual pays an additional
special contribution for services performed in Cyprus of
up to 1.75% their salary and up to 3.5% of earnings from
self-employment.
Relief for overseas employment
A Cypriot resident working outside Cyprus for a non-
Cypriot employer is exempt from taxation on their salary
that is attributable to their overseas duties if these duties
result in spending more than 90 days outside Cyprus in
a calendar year.
Relief for non-residents taking up employment in
Cyprus
Individuals physically present in Cyprus for less than 184
days in a calendar year are taxable in Cyprus only on
income derived from sources within, and employment
exercised in Cyprus.
A non-resident taking up employment and becoming
resident in Cyprus will be given a 20% tax-fee allowance
(capped at €8,550) on employment income for the
three years following the year of becoming resident in
Cyprus.
A 50% exemption applies to the employment income of
an individual that takes up employment in Cyprus where
that person was previously non-resident. This exemption
applies for a period of 5 years starting from the ?rst year
of employment provided that the annual employment
income of the employee exceeds €100,000 per annum.
6
The formation & uses of
Cyprus companies
Formation of companies
The Cypriot company
A Cypriot company can either be a private company
established by one or more persons or a public company
established by any seven or more persons who
cooperate for any legal purpose and form a limited
liability company, by signing the Memorandum of
Association and by complying with the provisions of the
Cyprus Companies Law.
A company’s constitutional documents are its
Memorandum and Articles of Association which specify
the activities in which the company may engage and the
means by which it will govern its affairs.
There is no minimum required issued and paid up capital
for a private company, however it is common to have
share capital of at least €1,000.
Every company must have a company secretary and a
registered of?ce address in Cyprus which may also be
used as the business address of the company. Although
not a requirement, it is common practice for the
majority of the directors to be Cypriot residents.
Company compliance
Every Cypriot company is required to maintain proper
books of account and to prepare audited ?nancial
statements in accordance with IFRS.
In accordance with Cypriot tax law, every company is
required to submit an annual corporate income tax
return.
There is also the requirement for annual ?nancial
statements prepared in Greek and a company annual
return to be submitted to the Registrar of Companies.
The translations are often undertaken by the local
advisers at minimal cost.
Cyprus - International Tax & Business Environment 7
Deloitte can assist with all aspects of conducting
business in Cyprus including arranging for the formation
of a Cypriot company, partnership or trust and the
ongoing administration and management of an entity.
Deloitte can co-ordinate audit, payroll and bookkeeping
services and Deloitte Human Capital Services can provide
assistance with recruitment of personnel as well as
obtaining work and residence visas, if required.
Common Cypriot companies
The equity holding company
A Cypriot holding company serves as a perfect gateway
to the EU, receiving dividends suffering no withholding
tax and paying dividends to shareholders without
deduction of withholding tax.
A Cypriot holding company serves as a perfect gateway
to the following countries with which Cyprus has
particularly advantageous tax treaties, receiving
dividends suffering no or little withholding tax and
paying dividends without deduction of withholding tax:
1. Russia – 1/3rd of all capital investment into Russia
?ows through Cyprus.
2. Ukraine – Cyprus is the biggest investor into Ukraine.
3. India – Cyprus has the sole right to tax capital gains
on sale of shares in a company that owns Indian
property, although Cyprus does not tax foreign
capital gains.
The oil and gas exploration & extraction company
Combined with Cyprus’s permanent establishment
exemption, exploration and extraction activity can be
undertaken free of Cypriot tax.
The ?nance and/or treasury company
A Cypriot company can receive interest on loans to EU
group companies with no withholding tax and can pay
interest without deduction of withholding tax. Other key
jurisdictions with no withholding tax on interest include
Russia and Ukraine.
A Cyprus company trading in securities (e.g. shares,
bonds, repos) will have no tax liability as income & gains
on disposal of such securities are exempt from Cypriot
tax.
Ship owning & management
Cyprus has the 10th largest merchant ?eet in the world
by registrations.
Speci?c tax exemptions apply to companies owning
ships or managing and employing crews working in
international waters. Cyprus has a very competitive
tonnage tax regime.
Regional employment company
Minimal Cypriot compliance obligations allow offshore
employees to be paid from Cyprus without Cypriot tax,
social security or other obligations.
8
Cyprus investment funds
The Cyprus fund industry
Investment funds are one of the up and coming sectors
within the Cyprus ?nancial services industry.
There are two types of funds that can be set up in
Cyprus: UCITS and non-UCITS, the latter known in Cyprus
as ICIS – International Collective Investment Schemes.
In addition there is the possibility to distribute foreign
UCITS and foreign non-UCITS in Cyprus.
UCITS may take the form of a:
• variable capital company; and
• mutual fund.
The International Collective Investment Schemes (ICIS)
may take the form of a:
• variable capital company;
• ?xed capital company;
• unit trust; and
• limited partnership.
An ICIS may be established with a limited or unlimited
duration and are designated as an:
• Experienced Investor Fund; or
• Private Investment Fund; or
• Retail Fund.
The ICIS fund offers plenty of advantages for the
experienced investor. While UCITS must comply with
speci?c investment and other restrictions, non-UCITS
collective investment schemes do not have any
restrictions on the percentage of assets held in particular
securities issued by a single issuer and have ?exible
requirements for the appointment of a custodian, fund
administrator or management company.
Taxation of investors
• There are no Cypriot taxes for investors in a Cypriot
fund on the disposal or redemption of fund units/
shares.
• There are no withholding taxes on distributions made
to non-Cypriot investors by a Cypriot fund.
Taxation of funds
• A fund is exempt from tax on the disposal of its
investments in fund units, shares, other equity
securities and bonds.
• A fund is exempt from tax on distributions received
from investments in funds and shares held either
directly or via special purpose vehicles.
• Interest income derived by a fund is subject to 12.5%
income tax (net of deductible expenses and foreign tax
credits available).
The Cyprus legislative and regulatory
framework provides unprecedented
opportunities for alternative managers
and investors and has tremendous
growth potential within the
alternatives market.
Cyprus - International Tax & Business Environment 9
Trusts
A trust is an attractive and effective structure for wealth
protection preservation for future generations. Trust
structures are also increasingly used for commercial and
charitable purposes.
The de?ning features of a trust comprise:
1. a con?dential identi?able legal arrangement created
by a settlor;
2. an equitable obligation or obligations;
3. binding trustees to deal with property (the trust
assets);
4. to which the trustees hold the legal title but hold it
separately from the trustees’ own property;
5. for the bene?t of bene?ciaries (who may include
settlors and trustees) and
• who include a bene?ciary or bene?ciaries who hold
equitable interests or rights in equity and
• to whom the trustees owe ?duciary (and other
fundamental) duties;
6. and/or for the bene?t of a charitable object.
The settlor places property or assets into a trust at its
establishment and has the right to add more property or
assets at a later date. A settlor may also declare in the
trust deed how the trust’s property and income should
be used.
The Cyprus international trust
In Cyprus, trust law is contained in both statute and case
law with many of the principles of equity and English
law that have a history of hundreds of years. The
primary law for Cyprus international trusts is the
International Trust Law of 1992-2012.
The law de?nes a Cyprus international trust as a trust
where:
• the settlor is not a resident of Cyprus in the year
preceding the year of settlement of the trust;
• the bene?ciaries are not residents of Cyprus in the
year preceding the year of settlement of the trust;
• at least one of the trustees is a permanent resident of
Cyprus.
The settlor may retain or be granted powers, rights and
interests in the trust property allowing great ?exibility to
adopt to changes in circumstances or objectives.
The validity of a Cyprus international trust and the
disposition of property to the trust is protected against
claims brought for contravention of any foreign laws nor
are they affected by the inheritance or succession laws
of Cyprus or of any foreign jurisdiction.
The procedure for establishing an international trust in
Cyprus is straight forward and can be arranged in a
relatively short period of time.
Taxation of trusts
Cyprus international trusts enjoy a tax status that
provides signi?cant opportunities.
• non-resident bene?ciaries are subject to tax in Cyprus
an income and pro?ts of the trust derived only from
sources within Cyprus;
• resident bene?ciaries are subject to tax in Cyprus an
income and pro?ts of the trust derived from sources
within and outside Cyprus.
Cyprus international trusts
10
Cyprus shipping
The Cyprus Shipping Industry
Deloitte is amongst the leaders in providing professional
services to the Shipping Community in Cyprus and has
an excellent reputation in shipping worldwide. Our
clients include the world’s largest ship management and
shipping companies operating through Cyprus as well as
leading shipping lines, cruise lines, ferries, ports and port
authorities.
The development of Cyprus into an international
maritime centre began in 1963 when the government
offered the ?rst incentives aimed at the encouragement
of ship ownership and the registration of vessels under
the Cyprus ?ag.
The accession of Cyprus to the European Union in 2004
boosted further the registration of vessels in the Cyprus
Registry as Cyprus is one of only two countries in the
European Union with an “Open Registry”.
In 2010 a new tonnage tax system was introduced with
approval of the European Commission. This tonnage tax
system includes most of the favourable features found in
tonnage tax systems of other EU countries and provides
incentives and bene?ts to all three main sectors of the
shipping industry, being ship owners, charterers and ship
managers.
In summary, advantages of the Cyprus tonnage tax
system include: no income tax on shipping pro?ts
including pro?ts from the sale of ships, no tax on
dividends paid from shipping pro?ts, no estate duty or
capital gains tax; no income tax in Cyprus for foreign
crew; no stamp duty on documents or mortgage deeds.
Today Cyprus ranks 10
th
in the world with over 1,000
ships exceeding 20 million gross tonnage. In addition to
tax incentives and the country’s excellent geographical
position, this achievement is due to the cost
competitiveness of the Cypriot Ship Registry, the Island’s
well-developed maritime infrastructure, its excellent
international relations as well as the high standard of
services offered to international shipping.
For further details on the shipping industry in Cyprus,
please refer to our publication Shipping in Cyprus. All
our publications are available at www.deloitte.com/cy.
Cyprus - International Tax & Business Environment 11
Our Services
Delivering outstanding service to all clients is our top
priority.
We, at Deloitte, offer our clients a broad range of fully
integrated services in areas that include Audit, Tax,
Consulting and Financial Advisory.
Our client service teams, under the leadership of a Lead
Client Service Partner, help create powerful business
solutions for organizations operating all over the world.
This integrated approach combines insight and
innovation with business knowledge and industry
expertise to help our clients exceed their expectations.
Audit & Enterprise Risk Services
In today’s changing global economy, businesses need
trusted advisors. Because our audit professionals take
time to understand our clients’ business and needs, we
help them identify major risks and opportunities over
and above performing the traditional ?nancial reporting
function. Deloitte in Cyprus offers our clients a broad
range of audit and enterprise risk services.
Our high quality audit services focus on attest services
ranging from ?nancial to non-?nancial matters and
other related audit and advisory services. In delivering
these services we adhere to the highest standards of
independence, professional objectivity and technical
excellence. Our audit services include statutory audits
of ?nancial statements, non-statutory audits and other
attest opinions, International Financial Reporting
Standards (IFRS) services and governance services.
Our Enterprise Risk Services (ERS) team helps clients
manage risk and uncertainty, from the boardroom to the
network. Deloitte professionals provide a broad array of
services that allow clients around the globe to better
measure, manage and control risk to enhance the
reliability of systems and processes throughout their
enterprise. Our ERS services include control and
assurance, internal audit and security & privacy.
Tax & Legal
The provision of taxation services is core to Deloitte’s
business both in Cyprus and in the international arena.
Deloitte has one of the largest teams of taxation experts
in Cyprus, providing a full range of business and
personal taxation services.
Our Tax Services team keeps our clients up to speed on
the developments that may affect their business, help
them interpret their signi?cance and integrate tax
considerations into their strategy. We are proud to
provide quality taxation advice and services to large
multinational groups, corporations, owner-managed
businesses, entrepreneurs and high net wealth
individuals in Cyprus and throughout the world.
Together with our network of selected independent
lawyers specialising in corporate law and other legal
matters our Tax Services team offers legal services to
clients and address any legal matters that may affect
their business.
Integrated Services
Our Integrated Services team provides a broad range of
professional services which are tailored to support both
international and local clients with of?ces in Cyprus and
also clients who elect to outsource speci?c accounting
and administration processes.
Our team of highly trained and suitably quali?ed
accounting professionals, recognise the speci?c needs of
our clients and offer an extensive range of accounting
and administrative services, providing the necessary
assistance and professional support to enable our clients
to operate their business enterprises smoothly and
ef?ciently.
Deloitte professionals can arrange for the formation
of a Cypriot company, partnership or trust as well as the
provision of corporate and secretarial services ensuring
that these fully comply with their statutory obligations.
We can coordinate the undertaking of increases in
company share capital, statutory reductions in capital,
mergers and demergers as well as other corporate
restructuring and voluntary liquidations of companies.
Our integrated services include accounting and payroll,
contract administrative and other, tax compliance and
formation & administration of companies, partnerships
and trusts.
12
Consulting Services
Our consultants help our clients improve business
performance and increase shareholder value. We
combine expert business strategy and ?nancial skills
with the ability to deliver major information technology
and business change programmes.
Our Consulting Services team provides solutions for
enterprise applications, technology integration, strategy
and operations as well as human capital advisory
services.
Wealth Advisory Services
Our Wealth Advisory team has the resources
and capabilities to deal with all aspects of the ?nancial
affairs of the high net worth client under one roof
and to look after the client’s ?nances on a long term
basis. We like to think that for our clients we become
their family ?nance director, someone who can be
relied upon to see that their ?nancial affairs are always
in order.
Our team provides practical and imaginative wealth
advisory solutions combining sound investment
advice, with tax ef?cient structures and long term
succession planning. In addition our team provides
transaction advice, international advice as well as family
of?ce services.
Investment Fund Services
Our Investment Fund Services team which includes
investment, tax, wealth advisory, accounting,
audit, corporate ?nance and consulting specialists
provides tailor made multi-disciplinary solutions to
investment funds.
The team can assist with the formation of a fund,
ongoing tax consulting and compliance, audit,
investment compliance and the raising and introduction
of capital.
Financial Advisory Services
Our Financial Advisory Services professionals provide
strategic and ?nancial advisory services to clients
throughout every phase of the economic cycle. By
managing our service offerings, we can extract synergies
from our deep specialisation to provide added value to
our clients.
Our Financial Advisory Services team provides corporate
?nance, M&A transaction and valuation services. The
team also undertakes reorganisation, forensic and
dispute resolution services and advice on grants &
incentives.
360° Service!
About Deloitte
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member ?rms, each
of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte
Touche Tohmatsu Limited and its member ?rms.
Deloitte Limited is the Cyprus member ?rm of DTTL. Deloitte Cyprus is among the nation’s leading professional services ?rms, providing audit, tax,
consulting and ?nancial advisory services through over 500 people in Nicosia, Limassol and Larnaca. Deloitte has the broadest and deepest range of skills
of any business advisory organisation, and we have a straightforward goal: to be recognised as the pre-eminent and most trusted professional services
?rm, famous for the calibre of our people and respected for the exceptional quality of our work. For more information, please visit the Cyprus ?rm’s
website at www.deloitte.com/cy.
Deloitte provides audit, tax, consulting, and ?nancial advisory services to public and private clients spanning multiple industries. With a globally
connected network of member ?rms in more than 150 countries, Deloitte brings world-class capabilities and deep local expertise to help clients succeed
wherever they operate. Deloitte’s approximately 200,000 professionals are committed to becoming the standard of excellence.
This publication has been written in general terms and therefore cannot be relied on to cover speci?c situations; application of the principles set out will
depend upon the particular circumstances involved and we recommend that you obtain professional advice before acting or refraining from acting on
any of the contents of this publication. Deloitte Limited would be pleased to advise readers on how to apply the principles set out in this publication to
their speci?c circumstances. Deloitte Limited accepts no duty of care or liability for any loss occasioned to any person acting or refraining from action as
a result of any material in this publication.
Deloitte Limited is a private company registered in Cyprus (Reg. No. 162812). Of?ces: Nicosia, Limassol, Larnaca.
©2013 Deloitte Limited. All rights reserved
Members of the Board of Directors
Christis M. Christoforou (Chief Executive Of?cer), Eleftherios N. Philippou, Nicos S. Kyriakides, Nicos D. Papakyriacou,
Athos Chrysanthou, Costas Georghadjis, Antonis Taliotis, Panos Papadopoulos, Pieris M. Markou, Nicos Charalambous,
Nicos Spanoudis, Maria Paschalis, Alexis Agathocleous, Alkis Christodoulides, Christakis Ioannou, Yiannos Ioannou, Paul Mallis,
Panicos Papamichael, Christos Papamarkides, George Martides, Kerry Whyte, Andreas Georgiou, Christos Neocleous,
Demetris Papapericleous, Andreas Andreou, Alecos Papalexandrou, George Pantelides, Panayiota Vayianou,
Michael Christoforou (Chairman Emeritus).
Our Of?ces in Cyprus
Nicosia Limassol Larnaca
24 Spyrou Kyprianou Avenue Maximos Plaza, Tower 1, 3rd ?oor Patroclos Tower, 4th ?oor
CY-1075 Nicosia, Cyprus 213, Arch. Makariou III Avenue 41-43, Spyrou Kyprianou Avenue
P.O.Box 21675 CY-3030 Limassol, Cyprus CY-6051 Larnaca, Cyprus
CY-1512 Nicosia, Cyprus P.O.Box 58466 P.O.Box 40772
CY-3734 Limassol, Cyprus CY-6307 Larnaca, Cyprus
Tel.: + 357 22360300 Tel.: + 357 25868686 Tel.:+ 357 24819494
Fax: + 357 22360400 Fax: + 357 25868600 Fax:+ 357 24661222
E-mail: [email protected] E-mail: [email protected] E-mail: [email protected]
For further information, visit our website at www.deloitte.com/cy
Contacts
For more information you may contact:
Pieris M. Markou Antonis Taliotis
Head of Tax Services Tax Services
E-mail: [email protected] E-mail: [email protected]
Paul Mallis Alecos Papalexandrou
Tax Services Tax Services
E-mail: [email protected] E-mail: [email protected]
Christos Papamarkides Charles Charalambous
Indirect Taxes Wealth Management Services
E-mail: [email protected] E-mail: [email protected]
Panos Papadopoulos Christos Neocleous
Integrated Services Integrated Services
E-mail: [email protected] E-mail: [email protected]
doc_628514214.pdf
International Tax &
Business Environment
Foreword
I am pleased to introduce our guide to the international tax and business
environment in Cyprus.
Cyprus is well placed literally and metaphorically as the gateway between
Europe and the rest of the world. The geographic location of Cyprus at the
eastern-most point of Europe, bordering three continents, as well as the
Cypriot tax and business environment make Cyprus the ultimate country
for investors and businesses moving into Europe and for European business
expanding internationally. Cyprus offers many key bene?ts that contribute to
the success of business and investments and Deloitte in Cyprus is well placed
to ensure this success.
Deloitte is known for its values of ethos, integrity, specialized knowledge and
professionalism. Our ongoing commitment to continuous investment in our
people and our deliverables is the key to our success and our ability to look
at business issues from every angle is what sets us apart.
Deloitte in Cyprus can coordinate with the Deloitte member ?rms around
the world and other advisers to assist entrepreneurs and groups investing
and operating through companies incorporated and tax resident in Cyprus.
In addition to intermediary holding and ?nance companies, our Tax Services
team can assist with establishing Cypriot companies to perform other
functions which can bene?t from the favorable tax system and business
environment in Cyprus, such as ?nancial companies, investment trading
companies, intellectual property holding companies, shipping companies
and companies for oil & gas exploration as well as Cypriot fund management
companies and collective investment funds.
Deloitte in Cyprus has the ability to offer practical solutions that are
adapted to the needs of all businesses. Whether considering establishment
in new markets, acquisitions or rationalization of current operations, our
professionals can assist in the planning and implementation. Deloitte in
Cyprus will ensure that investors and businesses will achieve signi?cant
bene?ts in these cross-border transactions and investments.
We at Deloitte Cyprus look forward to working with you.
Christis M. Christoforou
Chief Executive Of?cer
Contents
2-3 The Cyprus business environment
4-5 The Cyprus tax system
6-7 The formation & uses of Cyprus companies
8 Cyprus investment funds
9 Cyprus international trusts
10 Cyprus shipping
11-12 Our services
Contacts
Cyprus - International Tax & Business Environment 1
2
The Cyprus business
environment
Reputation and stability
Cyprus joined the European Union in 2004, resulting in
an economy offering a great number of advantages
within a common European market. The Euro was
adopted by Cyprus as its unit of currency on 1 January
2008, further con?rming the country’s macro-economic
stability and its commitment to low in?ation, low
interest rates and high growth.
Cyprus participates in the European Union’s internal
market where there is free movement of goods, services
and capital. European citizens are able to conduct
business, travel to, and live in Cyprus with no legal
restrictions.
Demonstrating a stable ?nancial and business-friendly
environment since the 1970s, Cyprus has attracted
foreign investment and capital ?ows for decades. The
country’s ?nancial and regulatory environment is
harmonized with that of the European Union and the
Cyprus tax system is aligned with European principles of
equality within the framework of the European Union
Code of Conduct for business taxation and
demonstrates a commitment by Cyprus to the OECD
against harmful tax practices.
In April 2009 the OECD included Cyprus on its original
white list as one of only 40 countries in the world that
have substantially implemented internationally agreed
tax standards, being the highest categorization possible.
Being on this OECD white list supports Cyprus’s position
as a sound and reputable environment from which
international business operates.
Strategic location
The island of Cyprus is situated in the eastern
Mediterranean at the hub of three continents, linking
Europe with the Middle East, Africa and Asia.
Cyprus is one hour by air from Athens, Egypt and Israel,
three hours from Dubai and Moscow and four hours
from London.
Cyprus is two hours ahead of Greenwich Mean Time
(GMT).
International familiarity
Banking & ?nancial regulation
Commercial banking follows the British and European
Union models and is of a very high standard. There are
currently over 40 Cypriot and international banks
operating in Cyprus.
The banking system conforms to EC Directives, under
the regulation of the constitutionally independent
Central Bank of Cyprus, as integrated with the
Eurosystem. The Bank’s governance is compatible with
the provisions of the Treaty establishing the European
Community and the Statute of the European System of
Central Banks and of the European Central Bank.
The Cyprus Securities and Exchange Commission (CySEC)
supervises and controls the operation of the Cyprus
Stock Exchange and the issuers of securities listed on the
Exchange.
The Central Bank and CySEC supervise and licence the
growing number of investment services companies,
collective investment schemes, brokerage ?rms,
investment consultants and mutual fund management
companies.
In recent years Cyprus has been voted
the most attractive European tax
regime by major business organisations
across Europe. Cyprus has been
commended for the stability of its tax
law, the consistency in interpreting its
tax legislation and its low tax rates.
This accolade shows how the Cyprus
tax system, combined with its frst-rate
infrastructure, highly skilled workforce
and membership of the European
Union has made Cyprus the
international business hub it is today.
Cyprus - International Tax & Business Environment 3
Legal system
Cyprus has a well-functioning common law legal system
based on principles established through historical links
with the United Kingdom.
The origin of Cyprus company law and other laws
regulating business is the laws of the UK, updated for
21
st
century business practice and harmonised with EC
Directives.
The familiarity of the legal and commercial systems
assists international business people in working within
the Cypriot commercial environment. English is spoken
universally and is the accepted language of business.
Political respectability
Cyprus has excellent diplomatic and economic relations
with the rest of Europe as well as, China, Russia, India,
North America and the countries of the Middle East.
As a result, Cypriot entities enjoy great respectability
around the world.
Telecommunications
Cyprus has a highly advanced telecommunications
infrastructure system with a number of companies
providing modern telecommunication products and
solutions.
Air transport
The two international airports in Cyprus are served by
over 35 international airlines. There are daily ?ights to
other European countries, Russia and the Middle East
including major hubs for onward and long haul
international destinations. New airport terminals at both
Larnaca and Pafos international airports can serve up to
10 million passengers per annum.
Economy
Cyprus has an open-market economy with the private
sector comprising the backbone of economic activity.
Private enterprise is greatly promoted and supported by
decades of consistent government policy.
Cyprus ranks amongst the top half of EU countries in
terms of GDP per capita (currently €20,700 per annum).
In recent years up to 2009 the economy grew at an
average rate of 4% in real terms and the unemployment
rate is in the region of 5% of the labour force. In
addition, in?ation has been relatively modest with
increases in the consumer price index in the region of
2.5% per annum in recent years.
High standard of living – low cost base centre
and skilled workforce
Economic indicators place Cyprus amongst the few
international ?nancial centres with low operational
costs. At the same time, the island offers a high
standard of living with an enjoyable climate and a very
low crime rate making it an ideal place to live and
conduct business.
The costs of setting-up and maintaining a structure in
Cyprus are low when it comes to incorporation costs
and fees for meeting Cypriot tax and company law
compliance obligations.
The cost of labour, rents and other infrastructure are
highly competitive and often lower than in other
European countries.
Cyprus has a young and ?exible work force, with
university education obtained predominantly in the UK
and the USA. The island ranks among the leading
countries in the world and the highest in the European
Union in respect of university graduates in proportion to
its population, with the percentage of graduates from
tertiary institutions being the highest in the EU.
4
The Cyprus tax system
Cyprus’s advantageous tax system
Cyprus has all the tax attributes expected from an
international ?nancial centre
The Cyprus tax legislation and its regulation is
predictable and straight forward in nature. Relations
between the business community and the tax authorities
are excellent and ensure the ef?cient taxation of the
commercial and ?nancial sector. By providing a
transparent and ef?cient environment, the tax system
enhances Cyprus’s competitiveness and contributes to
making Cyprus an attractive jurisdiction in which to
structure international operations.
Corporate tax rate
Cyprus has a corporate income tax rate of 12.5%. This is
the lowest corporate tax rate in the European Union.
Exemption from tax on dividend income
Dividend income is exempt from tax irrespective of its
source provided that the company paying the dividend
either engages directly or indirectly in more than 50% of
activities that give rise to non-investment income or the
tax burden on the dividend paying company’s income is
not lower than 6.25%.
Dividends are not considered to be sourced from
investment income if they are derived directly or
indirectly from trading subsidiaries.
No withholding taxes
Dividends paid to non-resident shareholders are exempt
from withholding tax in Cyprus. Also, no withholding
tax is imposed on interest paid from Cyprus as well as
on royalties paid from Cyprus in respect of intellectual
property exploited outside Cyprus. The nil withholding
tax rates apply irrespective of whether the recipient is a
body corporate or an individual, the country of
residence of the recipient or whether a relevant tax
treaty exists.
Capital gains and income tax exemption for
securities
Cyprus does not impose income or capital gains tax on
the pro?ts and gains derived from the disposal of
securities, irrespective of whether the pro?ts and gains
are considered to be of a revenue or capital nature.
Securities, as de?ned in the law, include shares, bonds,
debentures, founder’s shares and other securities of
companies or other legal persons and options over such
securities.
Capital gains and income tax exemption for real estate
Cypriot companies can be used to hold real estate or
other assets outside Cyprus with no Cypriot capital gains
tax implications on disposal of the assets as capital gains
tax only applies to gains on the disposal of immovable
property which is situated in Cyprus or unlisted shares in
a company which owns immovable property situated in
Cyprus.
Permanent establishment abroad
Pro?ts from a permanent establishment maintained
abroad are generally exempt from tax in Cyprus.
Income from intellectual property
Only 20% of the net pro?ts derived by a Cyprus
company from the exploitation of its intellectual property
is subject to tax at the normal corporate income tax rate
of 12.5%. The net pro?t is calculated after deduction of
all costs incurred in earning the income, including 20%
of the cost of the intellectual property in each of the ?rst
?ve years of ownership.
Interest deductibility
Interest incurred by a Cypriot company is generally
deductible if incurred in respect of funding the
acquisition of assets used in a business which derives
taxable income. Practice statements and case law
provide further guidance on deductibility of interest.
Thin capitalisation
Cyprus does not have any thin capitalization rules or
minimum capitalization requirements.
A wide network of tax treaties
Cyprus boasts an extensive network of tax treaties,
currently with more than 50 countries, including
countries in North America, Western and Eastern Europe
Cyprus has become a favored location
for international commerce as well as
for reputable multinationals seeking a
legitimate tax effcient jurisdiction –
raising Cyprus to a new level of
international business.
Cyprus - International Tax & Business Environment 5
as well as emerging markets such as China, India and
Russia.
Generally, most treaties provide for reduced or nil rates of
withholding tax on dividends, interest and royalties paid
from the treaty country and the avoidance of double
taxation in the case where a resident in one of the treaty
countries derives income from the other treaty country.
Unilateral tax credit relief
Relief for taxes paid abroad is in the form of a tax credit
if the respective income is subject to tax in Cyprus. The
relief is given unilaterally irrespective of the existence of
a double tax treaty. Where a treaty is in force, the treaty
provisions apply if more bene?cial. Where dividend
income is received from a company resident in the
European Union or if a tax treaty provides, an underlying
tax credit is also allowed to the Cypriot recipient of the
dividend against any tax payable on that income.
Advance rulings and prior approvals
The Cyprus tax authorities provide advance
interpretations of the law under a ruling system.
VAT
The headline Cypriot VAT rate is 18% (19% from 13
January 2014). Reduced VAT rates of 5% and 8% (9%
from January 2014) apply to some goods and services.
Capital & net worth taxes, capital & stamp duties
Cyprus does not have any annual capital taxes and net
worth taxes and there are no signi?cant capital and
stamp duties.
Reorganizations
Cyprus has fully adopted the EC Merger Directive and
therefore where a transaction is a “reorganization”, it is
exempt from corporate income tax, capital gains tax,
stamp duties and property transfer fees.
A reorganization generally includes a merger, division,
part-division, transfer of assets and exchange of shares
involving companies which are resident in Cyprus and/or
companies which are not resident in Cyprus.
Cross border mergers and re-domiciliation of
companies
Cyprus legislation allows for the merger of two or more EU
member companies, whether a merger of Cypriot or Cypriot
and non-Cypriot EU member companies and whether the
Cypriot company is the surviving company or not.
Non-Cypriot companies which are allowed by their
jurisdiction of incorporation to deregister in that
jurisdiction and register elsewhere are able to become
domiciled in Cyprus. Cypriot companies are also permitted
to deregister from the Cypriot Register of Companies and
become domiciled in another jurisdiction.
Cross-border and domestic mergers, as well as the
redomiciliation and change in jurisdiction of tax residency
are generally tax neutral, there being no Cypriot “exit
taxation” applied to such restructures.
Liquidation of a Cypriot company
No capital gains tax, income tax or any other taxes arise
on the liquidation of a Cypriot company owned by
nonresident shareholders, irrespective of the method of
liquidation.
Personal tax
Personal tax rates
The personal tax rates are progressive and reach a top
marginal tax rate of 35% on income in excess of
€60,000 per annum. An individual pays an additional
special contribution for services performed in Cyprus of
up to 1.75% their salary and up to 3.5% of earnings from
self-employment.
Relief for overseas employment
A Cypriot resident working outside Cyprus for a non-
Cypriot employer is exempt from taxation on their salary
that is attributable to their overseas duties if these duties
result in spending more than 90 days outside Cyprus in
a calendar year.
Relief for non-residents taking up employment in
Cyprus
Individuals physically present in Cyprus for less than 184
days in a calendar year are taxable in Cyprus only on
income derived from sources within, and employment
exercised in Cyprus.
A non-resident taking up employment and becoming
resident in Cyprus will be given a 20% tax-fee allowance
(capped at €8,550) on employment income for the
three years following the year of becoming resident in
Cyprus.
A 50% exemption applies to the employment income of
an individual that takes up employment in Cyprus where
that person was previously non-resident. This exemption
applies for a period of 5 years starting from the ?rst year
of employment provided that the annual employment
income of the employee exceeds €100,000 per annum.
6
The formation & uses of
Cyprus companies
Formation of companies
The Cypriot company
A Cypriot company can either be a private company
established by one or more persons or a public company
established by any seven or more persons who
cooperate for any legal purpose and form a limited
liability company, by signing the Memorandum of
Association and by complying with the provisions of the
Cyprus Companies Law.
A company’s constitutional documents are its
Memorandum and Articles of Association which specify
the activities in which the company may engage and the
means by which it will govern its affairs.
There is no minimum required issued and paid up capital
for a private company, however it is common to have
share capital of at least €1,000.
Every company must have a company secretary and a
registered of?ce address in Cyprus which may also be
used as the business address of the company. Although
not a requirement, it is common practice for the
majority of the directors to be Cypriot residents.
Company compliance
Every Cypriot company is required to maintain proper
books of account and to prepare audited ?nancial
statements in accordance with IFRS.
In accordance with Cypriot tax law, every company is
required to submit an annual corporate income tax
return.
There is also the requirement for annual ?nancial
statements prepared in Greek and a company annual
return to be submitted to the Registrar of Companies.
The translations are often undertaken by the local
advisers at minimal cost.
Cyprus - International Tax & Business Environment 7
Deloitte can assist with all aspects of conducting
business in Cyprus including arranging for the formation
of a Cypriot company, partnership or trust and the
ongoing administration and management of an entity.
Deloitte can co-ordinate audit, payroll and bookkeeping
services and Deloitte Human Capital Services can provide
assistance with recruitment of personnel as well as
obtaining work and residence visas, if required.
Common Cypriot companies
The equity holding company
A Cypriot holding company serves as a perfect gateway
to the EU, receiving dividends suffering no withholding
tax and paying dividends to shareholders without
deduction of withholding tax.
A Cypriot holding company serves as a perfect gateway
to the following countries with which Cyprus has
particularly advantageous tax treaties, receiving
dividends suffering no or little withholding tax and
paying dividends without deduction of withholding tax:
1. Russia – 1/3rd of all capital investment into Russia
?ows through Cyprus.
2. Ukraine – Cyprus is the biggest investor into Ukraine.
3. India – Cyprus has the sole right to tax capital gains
on sale of shares in a company that owns Indian
property, although Cyprus does not tax foreign
capital gains.
The oil and gas exploration & extraction company
Combined with Cyprus’s permanent establishment
exemption, exploration and extraction activity can be
undertaken free of Cypriot tax.
The ?nance and/or treasury company
A Cypriot company can receive interest on loans to EU
group companies with no withholding tax and can pay
interest without deduction of withholding tax. Other key
jurisdictions with no withholding tax on interest include
Russia and Ukraine.
A Cyprus company trading in securities (e.g. shares,
bonds, repos) will have no tax liability as income & gains
on disposal of such securities are exempt from Cypriot
tax.
Ship owning & management
Cyprus has the 10th largest merchant ?eet in the world
by registrations.
Speci?c tax exemptions apply to companies owning
ships or managing and employing crews working in
international waters. Cyprus has a very competitive
tonnage tax regime.
Regional employment company
Minimal Cypriot compliance obligations allow offshore
employees to be paid from Cyprus without Cypriot tax,
social security or other obligations.
8
Cyprus investment funds
The Cyprus fund industry
Investment funds are one of the up and coming sectors
within the Cyprus ?nancial services industry.
There are two types of funds that can be set up in
Cyprus: UCITS and non-UCITS, the latter known in Cyprus
as ICIS – International Collective Investment Schemes.
In addition there is the possibility to distribute foreign
UCITS and foreign non-UCITS in Cyprus.
UCITS may take the form of a:
• variable capital company; and
• mutual fund.
The International Collective Investment Schemes (ICIS)
may take the form of a:
• variable capital company;
• ?xed capital company;
• unit trust; and
• limited partnership.
An ICIS may be established with a limited or unlimited
duration and are designated as an:
• Experienced Investor Fund; or
• Private Investment Fund; or
• Retail Fund.
The ICIS fund offers plenty of advantages for the
experienced investor. While UCITS must comply with
speci?c investment and other restrictions, non-UCITS
collective investment schemes do not have any
restrictions on the percentage of assets held in particular
securities issued by a single issuer and have ?exible
requirements for the appointment of a custodian, fund
administrator or management company.
Taxation of investors
• There are no Cypriot taxes for investors in a Cypriot
fund on the disposal or redemption of fund units/
shares.
• There are no withholding taxes on distributions made
to non-Cypriot investors by a Cypriot fund.
Taxation of funds
• A fund is exempt from tax on the disposal of its
investments in fund units, shares, other equity
securities and bonds.
• A fund is exempt from tax on distributions received
from investments in funds and shares held either
directly or via special purpose vehicles.
• Interest income derived by a fund is subject to 12.5%
income tax (net of deductible expenses and foreign tax
credits available).
The Cyprus legislative and regulatory
framework provides unprecedented
opportunities for alternative managers
and investors and has tremendous
growth potential within the
alternatives market.
Cyprus - International Tax & Business Environment 9
Trusts
A trust is an attractive and effective structure for wealth
protection preservation for future generations. Trust
structures are also increasingly used for commercial and
charitable purposes.
The de?ning features of a trust comprise:
1. a con?dential identi?able legal arrangement created
by a settlor;
2. an equitable obligation or obligations;
3. binding trustees to deal with property (the trust
assets);
4. to which the trustees hold the legal title but hold it
separately from the trustees’ own property;
5. for the bene?t of bene?ciaries (who may include
settlors and trustees) and
• who include a bene?ciary or bene?ciaries who hold
equitable interests or rights in equity and
• to whom the trustees owe ?duciary (and other
fundamental) duties;
6. and/or for the bene?t of a charitable object.
The settlor places property or assets into a trust at its
establishment and has the right to add more property or
assets at a later date. A settlor may also declare in the
trust deed how the trust’s property and income should
be used.
The Cyprus international trust
In Cyprus, trust law is contained in both statute and case
law with many of the principles of equity and English
law that have a history of hundreds of years. The
primary law for Cyprus international trusts is the
International Trust Law of 1992-2012.
The law de?nes a Cyprus international trust as a trust
where:
• the settlor is not a resident of Cyprus in the year
preceding the year of settlement of the trust;
• the bene?ciaries are not residents of Cyprus in the
year preceding the year of settlement of the trust;
• at least one of the trustees is a permanent resident of
Cyprus.
The settlor may retain or be granted powers, rights and
interests in the trust property allowing great ?exibility to
adopt to changes in circumstances or objectives.
The validity of a Cyprus international trust and the
disposition of property to the trust is protected against
claims brought for contravention of any foreign laws nor
are they affected by the inheritance or succession laws
of Cyprus or of any foreign jurisdiction.
The procedure for establishing an international trust in
Cyprus is straight forward and can be arranged in a
relatively short period of time.
Taxation of trusts
Cyprus international trusts enjoy a tax status that
provides signi?cant opportunities.
• non-resident bene?ciaries are subject to tax in Cyprus
an income and pro?ts of the trust derived only from
sources within Cyprus;
• resident bene?ciaries are subject to tax in Cyprus an
income and pro?ts of the trust derived from sources
within and outside Cyprus.
Cyprus international trusts
10
Cyprus shipping
The Cyprus Shipping Industry
Deloitte is amongst the leaders in providing professional
services to the Shipping Community in Cyprus and has
an excellent reputation in shipping worldwide. Our
clients include the world’s largest ship management and
shipping companies operating through Cyprus as well as
leading shipping lines, cruise lines, ferries, ports and port
authorities.
The development of Cyprus into an international
maritime centre began in 1963 when the government
offered the ?rst incentives aimed at the encouragement
of ship ownership and the registration of vessels under
the Cyprus ?ag.
The accession of Cyprus to the European Union in 2004
boosted further the registration of vessels in the Cyprus
Registry as Cyprus is one of only two countries in the
European Union with an “Open Registry”.
In 2010 a new tonnage tax system was introduced with
approval of the European Commission. This tonnage tax
system includes most of the favourable features found in
tonnage tax systems of other EU countries and provides
incentives and bene?ts to all three main sectors of the
shipping industry, being ship owners, charterers and ship
managers.
In summary, advantages of the Cyprus tonnage tax
system include: no income tax on shipping pro?ts
including pro?ts from the sale of ships, no tax on
dividends paid from shipping pro?ts, no estate duty or
capital gains tax; no income tax in Cyprus for foreign
crew; no stamp duty on documents or mortgage deeds.
Today Cyprus ranks 10
th
in the world with over 1,000
ships exceeding 20 million gross tonnage. In addition to
tax incentives and the country’s excellent geographical
position, this achievement is due to the cost
competitiveness of the Cypriot Ship Registry, the Island’s
well-developed maritime infrastructure, its excellent
international relations as well as the high standard of
services offered to international shipping.
For further details on the shipping industry in Cyprus,
please refer to our publication Shipping in Cyprus. All
our publications are available at www.deloitte.com/cy.
Cyprus - International Tax & Business Environment 11
Our Services
Delivering outstanding service to all clients is our top
priority.
We, at Deloitte, offer our clients a broad range of fully
integrated services in areas that include Audit, Tax,
Consulting and Financial Advisory.
Our client service teams, under the leadership of a Lead
Client Service Partner, help create powerful business
solutions for organizations operating all over the world.
This integrated approach combines insight and
innovation with business knowledge and industry
expertise to help our clients exceed their expectations.
Audit & Enterprise Risk Services
In today’s changing global economy, businesses need
trusted advisors. Because our audit professionals take
time to understand our clients’ business and needs, we
help them identify major risks and opportunities over
and above performing the traditional ?nancial reporting
function. Deloitte in Cyprus offers our clients a broad
range of audit and enterprise risk services.
Our high quality audit services focus on attest services
ranging from ?nancial to non-?nancial matters and
other related audit and advisory services. In delivering
these services we adhere to the highest standards of
independence, professional objectivity and technical
excellence. Our audit services include statutory audits
of ?nancial statements, non-statutory audits and other
attest opinions, International Financial Reporting
Standards (IFRS) services and governance services.
Our Enterprise Risk Services (ERS) team helps clients
manage risk and uncertainty, from the boardroom to the
network. Deloitte professionals provide a broad array of
services that allow clients around the globe to better
measure, manage and control risk to enhance the
reliability of systems and processes throughout their
enterprise. Our ERS services include control and
assurance, internal audit and security & privacy.
Tax & Legal
The provision of taxation services is core to Deloitte’s
business both in Cyprus and in the international arena.
Deloitte has one of the largest teams of taxation experts
in Cyprus, providing a full range of business and
personal taxation services.
Our Tax Services team keeps our clients up to speed on
the developments that may affect their business, help
them interpret their signi?cance and integrate tax
considerations into their strategy. We are proud to
provide quality taxation advice and services to large
multinational groups, corporations, owner-managed
businesses, entrepreneurs and high net wealth
individuals in Cyprus and throughout the world.
Together with our network of selected independent
lawyers specialising in corporate law and other legal
matters our Tax Services team offers legal services to
clients and address any legal matters that may affect
their business.
Integrated Services
Our Integrated Services team provides a broad range of
professional services which are tailored to support both
international and local clients with of?ces in Cyprus and
also clients who elect to outsource speci?c accounting
and administration processes.
Our team of highly trained and suitably quali?ed
accounting professionals, recognise the speci?c needs of
our clients and offer an extensive range of accounting
and administrative services, providing the necessary
assistance and professional support to enable our clients
to operate their business enterprises smoothly and
ef?ciently.
Deloitte professionals can arrange for the formation
of a Cypriot company, partnership or trust as well as the
provision of corporate and secretarial services ensuring
that these fully comply with their statutory obligations.
We can coordinate the undertaking of increases in
company share capital, statutory reductions in capital,
mergers and demergers as well as other corporate
restructuring and voluntary liquidations of companies.
Our integrated services include accounting and payroll,
contract administrative and other, tax compliance and
formation & administration of companies, partnerships
and trusts.
12
Consulting Services
Our consultants help our clients improve business
performance and increase shareholder value. We
combine expert business strategy and ?nancial skills
with the ability to deliver major information technology
and business change programmes.
Our Consulting Services team provides solutions for
enterprise applications, technology integration, strategy
and operations as well as human capital advisory
services.
Wealth Advisory Services
Our Wealth Advisory team has the resources
and capabilities to deal with all aspects of the ?nancial
affairs of the high net worth client under one roof
and to look after the client’s ?nances on a long term
basis. We like to think that for our clients we become
their family ?nance director, someone who can be
relied upon to see that their ?nancial affairs are always
in order.
Our team provides practical and imaginative wealth
advisory solutions combining sound investment
advice, with tax ef?cient structures and long term
succession planning. In addition our team provides
transaction advice, international advice as well as family
of?ce services.
Investment Fund Services
Our Investment Fund Services team which includes
investment, tax, wealth advisory, accounting,
audit, corporate ?nance and consulting specialists
provides tailor made multi-disciplinary solutions to
investment funds.
The team can assist with the formation of a fund,
ongoing tax consulting and compliance, audit,
investment compliance and the raising and introduction
of capital.
Financial Advisory Services
Our Financial Advisory Services professionals provide
strategic and ?nancial advisory services to clients
throughout every phase of the economic cycle. By
managing our service offerings, we can extract synergies
from our deep specialisation to provide added value to
our clients.
Our Financial Advisory Services team provides corporate
?nance, M&A transaction and valuation services. The
team also undertakes reorganisation, forensic and
dispute resolution services and advice on grants &
incentives.
360° Service!
About Deloitte
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member ?rms, each
of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte
Touche Tohmatsu Limited and its member ?rms.
Deloitte Limited is the Cyprus member ?rm of DTTL. Deloitte Cyprus is among the nation’s leading professional services ?rms, providing audit, tax,
consulting and ?nancial advisory services through over 500 people in Nicosia, Limassol and Larnaca. Deloitte has the broadest and deepest range of skills
of any business advisory organisation, and we have a straightforward goal: to be recognised as the pre-eminent and most trusted professional services
?rm, famous for the calibre of our people and respected for the exceptional quality of our work. For more information, please visit the Cyprus ?rm’s
website at www.deloitte.com/cy.
Deloitte provides audit, tax, consulting, and ?nancial advisory services to public and private clients spanning multiple industries. With a globally
connected network of member ?rms in more than 150 countries, Deloitte brings world-class capabilities and deep local expertise to help clients succeed
wherever they operate. Deloitte’s approximately 200,000 professionals are committed to becoming the standard of excellence.
This publication has been written in general terms and therefore cannot be relied on to cover speci?c situations; application of the principles set out will
depend upon the particular circumstances involved and we recommend that you obtain professional advice before acting or refraining from acting on
any of the contents of this publication. Deloitte Limited would be pleased to advise readers on how to apply the principles set out in this publication to
their speci?c circumstances. Deloitte Limited accepts no duty of care or liability for any loss occasioned to any person acting or refraining from action as
a result of any material in this publication.
Deloitte Limited is a private company registered in Cyprus (Reg. No. 162812). Of?ces: Nicosia, Limassol, Larnaca.
©2013 Deloitte Limited. All rights reserved
Members of the Board of Directors
Christis M. Christoforou (Chief Executive Of?cer), Eleftherios N. Philippou, Nicos S. Kyriakides, Nicos D. Papakyriacou,
Athos Chrysanthou, Costas Georghadjis, Antonis Taliotis, Panos Papadopoulos, Pieris M. Markou, Nicos Charalambous,
Nicos Spanoudis, Maria Paschalis, Alexis Agathocleous, Alkis Christodoulides, Christakis Ioannou, Yiannos Ioannou, Paul Mallis,
Panicos Papamichael, Christos Papamarkides, George Martides, Kerry Whyte, Andreas Georgiou, Christos Neocleous,
Demetris Papapericleous, Andreas Andreou, Alecos Papalexandrou, George Pantelides, Panayiota Vayianou,
Michael Christoforou (Chairman Emeritus).
Our Of?ces in Cyprus
Nicosia Limassol Larnaca
24 Spyrou Kyprianou Avenue Maximos Plaza, Tower 1, 3rd ?oor Patroclos Tower, 4th ?oor
CY-1075 Nicosia, Cyprus 213, Arch. Makariou III Avenue 41-43, Spyrou Kyprianou Avenue
P.O.Box 21675 CY-3030 Limassol, Cyprus CY-6051 Larnaca, Cyprus
CY-1512 Nicosia, Cyprus P.O.Box 58466 P.O.Box 40772
CY-3734 Limassol, Cyprus CY-6307 Larnaca, Cyprus
Tel.: + 357 22360300 Tel.: + 357 25868686 Tel.:+ 357 24819494
Fax: + 357 22360400 Fax: + 357 25868600 Fax:+ 357 24661222
E-mail: [email protected] E-mail: [email protected] E-mail: [email protected]
For further information, visit our website at www.deloitte.com/cy
Contacts
For more information you may contact:
Pieris M. Markou Antonis Taliotis
Head of Tax Services Tax Services
E-mail: [email protected] E-mail: [email protected]
Paul Mallis Alecos Papalexandrou
Tax Services Tax Services
E-mail: [email protected] E-mail: [email protected]
Christos Papamarkides Charles Charalambous
Indirect Taxes Wealth Management Services
E-mail: [email protected] E-mail: [email protected]
Panos Papadopoulos Christos Neocleous
Integrated Services Integrated Services
E-mail: [email protected] E-mail: [email protected]
doc_628514214.pdf