The Cyprus Holding Company

The Cyprus Holding Company

Cyprus as an international financial centre is an ideal tax efficient gateway for investments in EU as well as non EU companies. It is widely used as an ultimate or intermediary holding company in a number of structures including the holding of operating, financing, real estate, as well as shipping companies.

Key features beneficial to the Cyprus Holding companies
KEY CRITERIA COMMENT
Incoming dividends Extensive double tax treaties, unilateral reliefs and EU Directives
Dividend income Generally non taxable
Outgoing dividends No withholding tax to non-residents
Capital Gains Full tax exemption of gains
Foreign PE profits Exempt
Reorganization and Group Relief Group relief is allowed and losses set off against future profits
Controlled Foreign company No CFC legislation
Thin Capitalization No provisions for debt to equity ratio
Transfer pricing No TP rules. Arm’s length principle applies
Redomiciliation Redomiciliation is permitted
Listing in international Stock Exchanges Tax efficient and easy process
Interest income Interest taxed only at 12,50 percent
Interest and Royalties Withholding No withholding taxes, only for royalties (10%) for their use in Cyprus
VAT Registration Holding activities are not obliged to register
Liquidation Distribution of assets without any tax
Stamp Duty Only for assets existing in Cyprus

The Cyprus Holding Company

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