Cyprus Limited Company
Cyprus
Cyprus has long been established as a popular EU jurisdiction for international tax planning, offering a 12.5% corporate tax rate — matching Ireland as the lowest in the EU — alongside an extensive double tax treaty network covering over 65 countries and a notional interest deduction regime for equity-funded businesses. The Cyprus Companies Law is based on English company law, making it familiar to common law practitioners. Despite historic banking sector difficulties following the 2013 bailout, banking has stabilised with Bank of Cyprus, Hellenic Bank, and various EMI alternatives accessible to international companies. Nominee director and shareholder structures are standard practice, though economic substance requirements have tightened since EU and OECD scrutiny increased.
Formation Details
- Setup Time
- 5 days
- Setup Cost
- $2,000
- Annual Cost
- $2,000
- Corporate Tax
- 12.5%
- VAT Threshold
- $19,000
- Nominee Directors
- Allowed
- Public Register
- Yes
- Residency Required
- No residency requirement for shareholders or directors. Nominee directors are widely available and commonly used. A registered office address in Cyprus is required. Substance requirements must be considered to maintain Cyprus tax residency status for the company.
- Banking Difficulty
- Moderate
US Person Considerations
US persons owning a Cyprus company must file Form 5471 for CFC reporting. Cyprus's 12.5% corporate tax rate means GILTI inclusions may apply on excess returns. The US-Cyprus tax treaty was terminated by the US in 2023, eliminating previously favourable withholding rate reductions. US owners should obtain specialist US international tax advice given the post-treaty landscape and Cyprus's historically high-risk classification for certain structures.