Knowledge base · CY

Cyprus

An EU member state with English-based company law, used for holding, financing, IP, shipping and fund vehicles; a 15% corporate tax rate since 2026 and a non-public beneficial-ownership register.

Cyprus pairs English-based company law with EU membership, a wide treaty network and a corporate tax system that exempts most dividends and gains on shares. That combination has made the private company limited by shares the usual holding and financing vehicle for groups whose owners and operations sit elsewhere.

The tax reform in force from 1 January 2026 changed the arithmetic. Corporate income tax rose from 12.5% to 15%. A company incorporated in Cyprus is now tax resident there by default. The deemed distribution of profits was abolished for 2026 profits onward, and the special defence contribution on dividends paid to Cyprus-resident, Cyprus-domiciled individuals fell to 5%. Payments to associated companies in jurisdictions on the EU list, or in low-tax jurisdictions named by the Tax Department, can now bear withholding or lose their deduction.

Cyprus has no private foundation law. Owners who want a foundation over a Cyprus holding company usually use one from Malta or Liechtenstein, or a Cyprus International Trust instead.

General information, not advice. Facts are stated as of the date on each page. Law, lists and rates change; the professional who acts for the entity confirms what applies to it. Chrysos performs no regulated act and gives no legal or tax advice.

Facts as of 30 October 2026

Beneficial ownership

Who is a beneficial owner: A natural person who ultimately owns or controls the entity — more than 25% of the shares or voting rights, held directly or through other entities, or control by other means. If no one qualifies, the senior managing officials are recorded.
Register: The Register of Beneficial Owners, kept by the Registrar of Companies, covers companies and partnerships. Branches of foreign companies and companies listed on an EU regulated market are outside it.
Deadlines: First filing within 90 days of incorporation; changes within 45 days of the company learning of them; an annual confirmation between 1 October and 31 December.
Who can see it: Not public since November 2022. Authorities have direct access; banks and other obliged entities see core details for customer due diligence. Law 25(I)/2026 replaced public access with access for those who show a legitimate interest.
Trusts: Express trusts administered by a Cyprus-resident trustee, including Cyprus International Trusts, are registered with CySEC within 15 days. General public access to that register was withdrawn in 2026.
Nominees: Holding shares or acting as director for another is a licensed administrative service. The nominee appears in the register of members; the person behind it is recorded in the beneficial-ownership register.
Penalties: €100, then €50 a day, capped at €5,000, charged to the entity. A knowingly false declaration is a criminal offence.

Lists and exchange of information

EU tax list: Not applicable to a member state. Cyprus itself applies defensive withholding and expense denial to payments to associated companies in listed and low-tax jurisdictions.
FATF and MONEYVAL: Not on the FATF grey or black list (June 2026 plenary). Evaluated by MONEYVAL, the Council of Europe's body.
Exchange of information: Common Reporting Standard since 2017 as an early adopter; a Model 1 FATCA agreement with the United States; EU DAC rules, including DAC6 mandatory disclosure.
Tax treaties: About 65 double tax treaties, and the EU Parent-Subsidiary and Interest and Royalties Directives.

6 forms

Legal entities

Company · Ltd

Private company limited by shares

Law: Companies Law, Cap. 113

The standard vehicle for owner-held structures. A separate legal person whose shareholders are liable only for unpaid share capital.

Members and officers: One to fifty shareholders; at least one director, corporate directors allowed; a company secretary; a registered office in Cyprus.
Share capital: No statutory minimum.
Public register shows: Name, number, status, registered office, directors and secretary. Filed documents, including the annual return with the shareholder list, can be ordered. Beneficial-ownership data is not public.
Accounts and audit: Annual IFRS financial statements, audited. A small private company may instead have a review by a licensed auditor. The HE32 annual return follows the annual general meeting.
Tax: 15% corporate income tax from 2026. Dividends received and gains on shares are generally exempt; no withholding on dividends or interest paid abroad, outside the defensive rules.

How owners use it

Intermediate holding company for EU and non-EU subsidiaries
Group financing company, taxed on its margin with transfer-pricing support
IP-owning company with real development activity, under the IP box
Regional headquarters, trading or ship-management company with staff in Cyprus
Family holding company for an owner who relocates to Cyprus

What comes with it

Tax residence is by incorporation from 2026, but treaties and banks still look for board decisions taken in Cyprus, with staff and premises that fit the activity
Payments to associated companies in EU-listed or low-tax jurisdictions can bear withholding or lose their deduction
Beneficial-ownership filings and the annual confirmation must match the register of members
Banks expect an ownership chart down to the natural persons, audited accounts and source of funds

Company · Plc

Public company limited by shares

Law: Companies Law, Cap. 113

A company that may offer its shares to the public. Rare in private structures; used when a listing or a bond issue is planned.

Share capital: Minimum issued capital of €25,629, certified by the Registrar before the company may trade or borrow.
Accounts and audit: Full audit; the review option for small companies does not apply.
Tax: As for a private company.

How owners use it

Listing or bond-issuing vehicle
Holding company of a group seeking an EU listing

What comes with it

Market and disclosure rules apply on top of company law once listed

Partnership

General and limited partnership

Law: Partnerships and Business Names Law, Cap. 116

Two or more partners in business together. General partners carry unlimited liability; limited partners are liable up to their contribution if they take no part in management.

Partners: At least two; a limited partnership needs at least one general and one limited partner. Registered with the Registrar.
Beneficial ownership: Treated as a legal entity for the beneficial-ownership register, with the same filings and annual confirmation.
Tax: Transparent; profits are taxed in the partners' hands. A partnership tax return is required from 2026.

How owners use it

Professional and joint-venture partnerships
Fund vehicle with a Cyprus general partner

What comes with it

Each partner's own residence and substance decide the tax result

Branch · Overseas company

Branch of a foreign company

Law: Companies Law, Cap. 113, section 347 onwards

A foreign company's place of business in Cyprus, registered within a month of opening. Not a separate legal person.

Registration: The foreign company's constitution, register details, capital and authorised representatives in Cyprus.
Beneficial ownership: Outside the Cyprus register; the foreign company's own register applies.
Tax: Profits of the Cyprus permanent establishment are taxed at 15%.

How owners use it

A regional team of a foreign group without a subsidiary

What comes with it

Banks ask for the parent's documents and ownership chain as well as the branch's

Trust · CIT

Cyprus International Trust and domestic trust

Law: International Trusts Law 69(I)/1992; Trustees Law, Cap. 193

A trust governed by Cyprus law. Trustees hold the assets; the trust has no legal personality. A Cyprus International Trust has a settlor who was not resident in Cyprus in the year before it was created.

Trustees: At least one Cyprus-resident trustee for a CIT. Professional trustees are licensed by CySEC or supervised by the Bar Association or ICPAC.
Register: Registered with CySEC within 15 days of the trustee's appointment, naming settlor, trustees, protector and beneficiaries or their class. Not public.
Tax: Non-resident beneficiaries are taxed in Cyprus only on Cyprus-source income. Cyprus has no inheritance tax.

How owners use it

Holding family company shares for succession and continuity
Employee benefit and charitable trusts

What comes with it

Every settlor, trustee, protector and beneficiary is a beneficial owner, whatever their share
The trustee must genuinely control the assets; a trust run by its settlor invites challenge

Fund · AIF · RAIF · AIFLNP

Alternative investment fund, registered AIF and AIF with limited persons

Law: Alternative Investment Funds Law 124(I)/2018

Regulated fund vehicles as a common fund, an investment company or a limited partnership. A registered AIF is listed by CySEC rather than authorised and must be run by an external authorised manager.

Oversight: CySEC authorisation (AIF) or listing (RAIF), a depositary and an auditor. A RAIF is open only to professional and well-informed investors.
Beneficial ownership: Funds report changes within 45 days of each net-asset-value calculation.
Tax: A corporate fund pays 15%, with the dividend and share-gain exemptions; no withholding on distributions to non-residents.

How owners use it

Private equity, real estate and venture vehicles
Pooling family-office investments under an external manager

What comes with it

Real management by the licensed manager; the investors do not run the fund

Sources

Facts as of 30 October 2026

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