Cyprus ey.com/GlobalTaxGuides
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Philippos Raptopoulos
Business Tax Advisory
Philippos Raptopoulos
Global Compliance and Reporting
Myria Saparilla
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Petros Krasaris
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International Tax and Transaction Services — Transaction Tax Advisory
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Panayiotis Tziongouros
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Petros Liassides
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Tax Technology and Transformation
Simos Simou
Global Compliance and Reporting
Petros Liassides
People Advisory Services
Panayiotis Thrasyvoulou
Indirect Tax
George Liasis
A. At a glance
Corporate Income Tax Rate (%)
Capital Gains Tax Rate (%)
Branch Tax Rate (%)
Withholding Tax (%)
Dividends
+357 22-209-894
Email: simos.simou@cy.ey.com
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(a)(b)
Interest 0 (b)(c)
Royalties from Patents, Know-how, etc. 0/5/10 (b)(d)
Branch Remittance Tax
Net Operating Losses (Years)
Carryforward
(a) A Special Contribution to the Defence Fund (Defence Tax) at a rate of 17% is withheld from dividends paid (or deemed to be paid) to resident and domi ciled individuals.
(b) Cyprus introduced withholding tax on dividends, interest and royalties made to companies that are resident in jurisdictions included on the European Union (EU) list of non-cooperative jurisdictions on tax matters (Annex I) or are registered in a jurisdiction listed by the EU as non-cooperative for tax matters and not considered to be tax resident in another jurisdiction that is not included on the EU list. Such withholding taxes are applicable as of 31 December 2022. Also, see Dividends in Section B.
(c) A Special Contribution to the Defence Fund (Defence Tax) at a rate of 30% is withheld from interest paid to resident companies and resident and domi ciled individuals, if the interest is either not considered to arise in the ordi nary course of the business of the recipient or is not closely connected to the ordinary course of business of the recipient.
(d) Cyprus levies withholding tax on payments made to nonresident persons who do not carry on any business in Cyprus at a rate of 10% on technical assis tance payments and on the gross amount of royalty payments that are con nected with the economic utilization of intellectual property rights in Cyprus. A 5% rate applies to royalties paid with respect to films and television. A 5% withholding tax is also imposed on payments made to nonresident persons in consideration for services performed in Cyprus with respect to activities con nected with the exploration or exploitation of the seabed or subsoil or their natural resources or with respect to activities relating to the installation and exploitation of pipelines and other installations on the subsoil, seabed or sea surface, if such payments are not connected with a permanent establishment in Cyprus. Withholding tax may be reduced or eliminated on the basis of the European Union (EU) Interest and Royalty Directive and/or on the basis of a double tax treaty.
B. Taxes on corporate income and gains
Corporate income tax. Companies resident in Cyprus are subject to income tax on their worldwide income. A company is resident in Cyprus if its control and management are exercised in Cyprus. Nonresident companies are taxed only on income derived from a permanent establishment in Cyprus and on rental income from property located in Cyprus.
As of 31 December 2022, a company incorporated or registered in Cyprus whose management and control is exercised outside Cyprus will be considered resident for tax purposes of Cyprus unless such company is a tax resident in another country.
Rate of corporate tax. The standard rate of corporate income tax is 12.5%.
Capital gains. A capital gains tax of 20% is levied on gains de rived from the disposal of the following:
• Immovable property located in Cyprus
• Shares in companies whose assets include, among others, im movable property located in Cyprus
• Shares in companies that participate (either directly or indirect ly) in a company or companies that own immovable property located in Cyprus and at least 50% of the market value of such shares is derived from the relevant property
• A sale agreement of immovable property located in Cyprus.
The disposal of shares of companies listed on a recognized stock exchange is exempt from capital gains tax. In addition, no capital gains tax is imposed if the transfer is made in the course of a qualifying company reorganization.
The gain subject to tax in Cyprus equals the disposal proceeds less the greater of the cost or market value on 1 January 1980, adjusted for inflation. Inflation is calculated using the official Retail Price Index. In the case of disposal of shares of companies that directly or indirectly hold property in Cyprus, the disposal proceeds subject to capital gains are restricted to the market value of the immovable property held directly or indirectly by the com pany whose shares are sold.
Gains from the disposal of immovable property that consists of land or land and buildings is exempt from capital gains tax if the property is acquired between 16 July 2015 and 31 December 2016 from an independent third party and not through an exchange of property or through a donation or gift.
Administration. The tax year in Cyprus is the same as the calen dar year. Income tax is payable by 31 August following the end of the relevant tax year. However, an estimate of tax due is made by 31 July during the tax year and provisional tax is payable in two equal installments by 31 July and 31 December. The two provisional payments can be made by 31 August and 31 January without the imposition of interest or penalties.
Overdue tax is subject to interest (currently at the rate of 1.75% per year) on the basis of complete months. In addition, a flat 5% penalty is imposed on the tax due in the event of a failure to pay the tax by the due date. An additional penalty of 5% is imposed if the outstanding tax is not paid within two months after the due date.
Dividends. Dividends paid to nonresident persons are generally not subject to withholding tax. However, Cyprus introduced withholding tax on dividends paid to companies that are resident or are registered in a jurisdiction listed by the EU as non-cooperative for tax matters (Annex I of the EU list). Such withholding tax is applicable as of 31 December 2022. More specifically, dividends paid by a Cypriot tax resident company to
a company that is a resident in a jurisdiction that is included on the EU list, or to a company incorporated or registered in a jurisdiction included on the EU List and not considered to be tax resident in another jurisdiction that is not included on the EU List, will be subject to 17% withholding tax on the amount of the dividend paid.
The withholding tax applies if the company receiving the divi dend is included on the EU list and if such company participates directly in the Cypriot company paying the dividend by more than 50% in voting rights, owns more than 50% of the share capital or is entitled to 50% or more of the profits of the Cypriot company. In addition, withholding tax shall apply if two or more associated enterprises that are included on the EU list participate directly in the Cypriot company paying the dividend and collec tively have more than 50% in voting rights, own more than 50% of the share capital or are entitled to 50% or more of the profits of the Cypriot company. However, no withholding tax will be imposed on dividends paid with respect to securities listed on a recognized stock exchange.
A 17% Special Contribution to the Defence Fund (Defence Tax) is withheld from dividends paid to resident and domiciled indi viduals. This is a final tax. Also, see Section D.
A Cypriot tax resident company is deemed to have distributed as dividends 70% of its after-tax accounting profits (subject to cer tain adjustments) two years after the end of the relevant tax year (for example, the deemed distribution date for the 2020 tax year is 31 December 2022). The amount of the deemed dividend is reduced by any actual dividend distributions made up to the deemed distribution date relating to the year whose profits are subject to deemed distribution. The Special Contribution to the Defence Fund (Defence Tax) is withheld only on the proportion of profits that is attributable to shareholders considered to be residents of Cyprus (individuals and bodies of persons).
The deemed distribution rules do not apply to profits that are directly or indirectly attributable to shareholders that are non residents of Cyprus and/or to individual shareholders that are Cypriot tax residents but do not have a domicile in Cyprus.
Interest. Interest paid to nonresident persons is generally not subject to withholding tax. However, as of 31 December 2022, withholding tax at a rate of 30% will be imposed on interest re ceived by or credited to a company that is resident in a jurisdiction included on the EU list, or to a company that is incorporated or registered in a jurisdiction included on the EU list and is not resident in another jurisdiction that is not included on the EU list, if the interest is derived from sources within Cyprus. However, no withholding tax shall apply on any interest payments made by an individual. In addition, no withholding tax will be imposed on interest received by or credited to a non-Cypriot tax resident com pany with respect to securities listed on a recognized stock ex change.
Foreign tax relief. Foreign tax on profits and gains of Cypriot resident persons is credited against the tax payable in Cyprus on the same profits or gains (pooling of credits is generally not allowed). Such foreign tax relief cannot exceed the Cyprus tax
payable on the same profits or gains. Any unused foreign tax relief cannot be carried forward.
C. Determination of trading income
General. The determination of taxable income is based on ac counts prepared in accordance with generally accepted account ing principles, subject to certain adjustments and provisions of the tax law. Expenses must be incurred wholly and exclusively for the generation of income and must be supported by relevant evi dence.
Notional interest deduction on equity. As of 1 January 2015, Cyprus tax resident companies (as well as foreign companies having a permanent establishment in Cyprus) that carry on a business are entitled to claim a notional interest deduction (NID) on their equity capital. The NID is deducted from the taxable in come of the entity for the relevant tax year (subject to any restric tions) for the period within the tax year during which the equity belongs to the entity and is used by that entity for the carrying on of its activities. The NID equals the “reference interest rate” mul tiplied by the “new capital” (the NID cannot be claimed on “old capital”).
The NID granted on new capital cannot exceed 80% of the tax able profit before allowing for NID. In the event of losses, the NID will not be available. Effectively, this means that NID cannot create or increase tax losses.
Taxpayers can elect not to claim NID or claim part of it for each tax year.
Inventories. Inventory is generally valued at the lower of cost or net realizable value. The cost must be determined under the firstin, first-out method and/or the weighted average cost formula. The last-in, first-out method is not acceptable.
Depreciation and amortization allowances
Plant and machinery. A straight-line allowance of 10% a year is given on capital expenditures for plant and machinery. For ma chinery and plant acquired during the period of 2012 through 2018, a deduction for wear and tear at 20% per year is allowed.
Industrial buildings. A straight-line allowance of 4% a year is available for industrial buildings. For industrial and hotel build ings acquired during the period of 2012 through 2018, a deduc tion for wear and tear at 7% is allowed.
Commercial buildings. A straight-line allowance of 3% a year is allowed for commercial buildings.
Office equipment. A straight-line allowance of 20% a year is allowed for computers. Other office equipment is depreciated under the straight-line method at an annual rate of 10%. For other office equipment acquired during the period of 2012 through 2018, a deduction for wear and tear at a rate of 20% per year is allowed.
Motor vehicles. In general, a straight-line allowance of 20% a year is allowed for motor vehicles (except for private saloon cars for which no tax depreciation is available).
Sales of depreciable assets. On the disposal of an asset, a socalled balancing statement must be prepared. If the sale proceeds are less than the remaining depreciable base, a further allowance (balancing deduction) equal to the amount of the difference is granted. If the sale proceeds exceed the depreciable base, the excess (up to the amount of allowances claimed) is included in taxable income (balancing addition). As of 1 January 2020, the obligation to prepare a balancing statement does not apply to in tangible assets.
Taxation of intangible assets
New Intellectual Property Box regime. The provisions of the Intellectual Property (IP) Box regime have been aligned with the recommendations of the Organisation for Economic Co-operation and Development (OECD) Action 5 of the Base Erosion and Profit Shifting (BEPS) Plan on Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance.
The new IP Box regime is based on the OECD-recommended nexus approach. This approach limits application of the IP Box regime if research and development (R&D) is being outsourced to related parties. The approach links the benefits of the regime with the R&D expenses incurred by the taxpayer. Under the new IP Box regime, qualifying taxpayers can claim a tax deduction equal to 80% of qualifying profits resulting from the business use of the qualifying assets. A taxpayer may elect not to claim the deduction or only claim a part of it. The following is the calculation for qualifying profits:
Qualifying expenditure + Uplift expenditure x Overall IP income Overall expenditure
The cost of the acquisition or development of intangible assets of a capital nature is amortized in a reasonable manner over its use ful economic life, which is determined based on accounting standards, with a maximum period of 20 years. Taxpayers may claim all or part of the amortization for tax purposes. Any unused amortization can be carried forward and used in future tax years.
Old IP Box regime. The grandfathering provisions of the old IP Box regime expired on 30 June 2021.
Relief for losses. Effective from 1 January 2012, losses can be carried forward to the following five years. Loss carrybacks are not allowed.
Group loss relief. Group loss relief for losses incurred in the income year is allowed between resident group companies that meet certain conditions.
Effective from 1 January 2015, the group loss relief provisions were extended to cases in which the surrendering company is registered in and is a tax resident of another EU member state, provided that it has exhausted all possibilities available for using the losses in its respective country of tax residency or in the country where its intermediary holding company has its seat. In such circumstances, the tax losses are calculated based on the provisions of the Cypriot tax laws.
Cyprus does not have any tax consolidation rules, and companies are required to submit a stand-alone income tax return.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax Rate (%)
Value-added tax (VAT), on any supply of goods or services, other than an exempt supply, made in Cyprus by a taxable person (taxable if annual supplies exceed EUR15,600) in the course of business 0/5/9/19
Payroll taxes
Social insurance contribution, levied on each employee’s gross salary, up to EUR4,840 a month; payable by both employer and employee 8.3
Employer’s contribution to the National Health System; contributions are capped to yearly emoluments of EUR180,000 2.9
Employee’s contribution to the National Health System; contributions are capped to yearly emoluments of EUR180,000 2.65
Special Cohesion Fund, levied on gross salary; payable by employer 2
Human Resource Development Authority and Redundancy Fund, levied on gross salary, up to EUR4,840 a month; paid by employer 1.7 Leave Fund, levied on gross salary, up to EUR4,840 a month; paid by employer in lieu of holiday pay for employees working 5 days per week and who are entitled to 20 days annual leave (employers may obtain exemption from contributions to this fund) 8
Special Contribution to the Defence Fund (Defence Tax)
On rents received (after allowing for a 25% deduction; the deduction is only available to individuals) 3 On interest received (except for interest earned in the ordinary course of business) 30 On dividends received (or deemed to be received) by resident and domiciled individuals 17
E. Miscellaneous matters
Foreign-exchange controls. Cyprus does not impose foreignexchange controls.
Transfer pricing. The arm’s-length principle is codified in the Cyprus tax law with language similar to that of Article 9 of the OECD Model Tax Convention. Consequently, all transactions entered into with related and/or connected parties must be con cluded on an arm’s-length basis; otherwise, the tax authorities have the statutory right to make adjustments to taxable income. Therefore, the arm’s-length price must be applied on transactions between related parties in their commercial or financial relations. However, Cyprus does not have specific rules regarding transfer pricing or transfer-pricing documentation requirements (apart from loans financed out of debt as detailed below).
On 30 June 2017, the Cyprus Tax Department issued a circular establishing transfer-pricing documentation requirements and rules for Cypriot enterprises engaged in intragroup financing transactions with affiliated and connected parties (granting of loans to related parties that are financed by debt). The circular provides general guidance on the application of the arm’s-length principle according to the OECD Transfer Pricing Guidelines. A transfer-pricing comparability analysis should be prepared by relevant taxpayers to determine their functional profile and to document whether the agreed remuneration (the net interest mar gin) complies with the arm’s-length principle. In addition, certain simplification measures apply to companies whose functional profile is similar to regulated financing and treasury enterprises and to entities engaged in pure intermediary activities.
Broader transfer-pricing legislation is expected to be introduced during 2022 to align the local practice with the OECD Transfer Pricing Guidelines. The broader legislation will capture the entire range of intercompany transactions and is expected to introduce a requirement to prepare both a Local and Master File (based on the recommendation of BEPS Action 13). In addition, corporate taxpayers will be expected to submit a Summary Information Table within nine months from the corresponding year-end, pro viding core information regarding the type and volume of related-party transactions as well as information with respect to the counterparties.
EU Anti-Tax Avoidance Directive. The Cypriot tax laws have been amended to incorporate the relevant provisions of the EU AntiTax Avoidance Directive (ATAD). The amendments made in 2019 and 2020 are summarized below. The Cypriot tax authori ties have not yet issued any guidance or interpretative circular with respect to any of the ATAD-related provisions; however, it is expected that guidance will be issued during 2022 with respect to the interest limitation and CFC rules.
General anti-abuse rule. The amendments include a broadly worded general anti-abuse rule in line with the wording used in the ATAD.
Interest limitation rules. The interest limitation rules restrict the tax deductibility of exceeding borrowing costs (as defined) to 30% of the tax-adjusted earnings before interest, taxes, depreciation and amortization (EBITDA). The most important aspects of the interest limitation rules are the following:
• The interest limitation rules apply at a Cypriot group level (75% criterion).
• A de minimis exception applies for exceeding borrowing costs up to EUR3 million.
• An exemption applies to stand-alone entities and to financial institutions.
• Grandfathering rules apply to loans concluded before 17 June 2016.
• Long-term public infrastructure loans are excluded.
• Equity-escape clause measures are provided.
• Carryforward measures for unused interest capacity and for exceeding borrowing costs whose deductibility is restricted are provided.
Controlled foreign corporations. Controlled foreign corporation (CFC) rules are applicable in Cyprus as of 1 January 2019. If certain conditions are met, a Cypriot controlling taxpayer must include in its tax base the non-distributed income of a CFC com pany to the extent such profits arise from non-genuine arrange ments that have been put in place for the essential purpose of obtaining a tax advantage under the Cypriot Income Tax Law. An arrangement or series thereof is regarded as non-genuine to the extent that the significant people functions that have contributed to the generation of the income of the CFC are substantially performed by the Cypriot controlling company and/or other Cypriot persons associated with the Cypriot controlling company.
Exit taxation rules. As of 1 January 2020, a company that is tax resident in Cyprus or a non-Cypriot tax resident company that has a permanent establishment in Cyprus is subject to tax at an amount equal to the market value of the transferred assets at the time of exit, less their value for tax purposes, in any of the fol lowing cases:
• A Cypriot tax resident company transfers asset(s) from its head office in Cyprus to its permanent establishment in another EU member state or in a third country in so far as Cyprus no longer has the right to tax the transferred assets due to the transfer.
• A non-Cypriot tax resident company with a permanent estab lishment in Cyprus transfers assets from its permanent estab lishment in Cyprus to its head office or another permanent establishment in another EU member state or in a third country in so far as Cyprus no longer has the right to tax the transferred assets due to the transfer.
• A Cypriot tax resident company transfers its tax residence from Cyprus to another EU member state or to a third country, except for those assets that remain effectively connected with a perma nent establishment in Cyprus and for which Cyprus maintains its right to tax.
• A non-Cypriot tax resident company with a permanent estab lishment in Cyprus transfers the business carried on by its permanent establishment from Cyprus to another EU member state or to a third country in so far as Cyprus no longer has the right to tax the transferred assets due to the transfer.
Anti-hybrid rules. Rules against hybrid mismatches are applicable as of 1 January 2020 (with the exception of rules against reverse hybrids, which are effective as of 1 January 2022). The aim of the rules is to ensure that deductions or credits are only taken in one jurisdiction and that there are no situations involving deductions of payments in one country without taxation of the corresponding income in the other country concerned. The rules are typically limited to mismatches as a result of hybridity and do not affect the allocation of taxing rights under a tax treaty. The following are the rules:
• Hybrid financial instrument mismatches: Situations in which the qualification of a financial instrument or the payment made under it differs between two jurisdictions (for example, the instrument is considered to be debt in the payer jurisdiction and as equity in the payee jurisdiction).
• Hybrid entity mismatches: Situations in which an entity is qualified as opaque under the laws of one jurisdiction (that is,
a taxable entity under the laws of that jurisdiction) and quali fied as transparent by another jurisdiction (for example, the partners of the entity are taxable on their profit shares under the laws of that other jurisdiction).
• Hybrid transfers: Situations in which the laws of two jurisdic tions differ on whether the transferor or the transferee of a financial instrument has the ownership of the payments on the underlying asset.
• Hybrid permanent establishment mismatches: Situations in which the business activities in a jurisdiction are treated as being carried on through a permanent establishment by one jurisdiction while those activities are not treated as being car ried on through a permanent establishment in the other jurisdic tion.
• Imported mismatches: Situations in which the effect of a hybrid mismatch between parties in third countries is shifted into the jurisdiction of an EU member state through the use of a nonhybrid instrument thereby undermining the effectiveness of the rules that neutralize hybrid mismatches. This includes a deductible payment in an EU member state under a non-hybrid instrument that is used to fund expenditure involving a hybrid mismatch.
• Tax residency mismatches: Situations in which a taxpayer is resident for tax purposes in two or more jurisdictions.
Mergers and demergers. Exemptions are available for profits or gains arising as part of a qualifying company reorganization. However, the law includes general anti-abuse provisions that aim to ensure that the exemptions are available to bona fide company reorganizations. The exemptions also extend to stamp duty and land transfer fees.
F. Treaty withholding tax rates
As noted in Section A, Cyprus does not impose outbound with holding taxes on dividend and interest payments made to nonCypriot tax resident persons with the exception of certain payments made to companies that are registered in a jurisdiction included on the EU list of non-cooperative jurisdictions on tax matters (Annex I) and not considered to be tax resident in anoth er jurisdiction that is not included on the EU list. Also, see Dividends and Interest in Section B.
Dividends
Andorra
Armenia
Austria
Azerbaijan (z)
Bahrain
Barbados
Belarus
Belgium
Bosnia and Herzegovina (aa)
Bulgaria
Canada
(u)
Interest Royalties
(b)
(a)
(d)
(h)
(hh)
(ii)
(b) 0/10 (r)
Dividends Interest Royalties % % %
China Mainland 10 10 10
Czech Republic 0/5 (y) 0 10
Denmark 0/15 (s) 0 0
Egypt 5/10 (ss) 10 10 Estonia 0 0 0
Ethiopia 5 0/5 (b) 5
Finland 5/15 (l) 0 0
France 10/15 (f) 0/10 (e) 0/5 (g)
Georgia 0 0 0
Germany 5/15 (m) 0 0
Greece 25 10 0/5 (g)
Guernsey 0 0 0
Hungary 5/15 (h) 0/10 (b) 0
Iceland 5/10 (jj) 0 5
India 10 0/10 (b) 10
Iran 5/10 (ff) 0/5 (gg) 6 Ireland 0 0 0/5 (g)
Italy 15 10 0
Jersey 0 0 0
Kazakhstan 5/15 (tt) 0/10 (b) 10 Kuwait 0 0 5 Kyrgyzstan (z) 0 0 0
Latvia 0/10 (kk) 0/10 (ll) 0/5 (mm)
Lebanon 5 0/5 (b) 0 Lithuania 0/5 0 5 Luxembourg 0/5 (j) 0 0
Malta 0/15 (nn) 0/10 (b) 10 Mauritius 0 0 0
Moldova 5/10 (h) 5 5 Montenegro (aa) 10 10 10
Norway 0/15 (oo) 0 0
Poland 0/5 (cc) 0/5 (b) 5 Portugal 10 10 10 Qatar 0 0 5 Romania 10 0/10 (b) 0/5 (c)
Russian Federation 5/15 (k) 0/5/15 (uu) 0 San Marino 0 0 0
Saudi Arabia 0/5 (qq) 0 5/8 (rr)
Serbia (aa) 10 10 10 Seychelles 0 0 5
Singapore 0 0/7/10 (o) 10
Slovak Republic (bb) 10 0/10 (v) 0/5 (r)
Slovenia 5 0/5 (v) 5
South Africa 5/10 (dd) 0 0
Spain 0/5 (j) 0 0
Sweden 5/15 (h) 0/10 (b) 0 Switzerland 0/15 (ee) 0 0
Syria 0/15 (d) 0/10 (b) 10/15 (n)
Thailand 10 0/10/15 (p) 5/10/15 (q)
Ukraine 5/10 (w) 0/5 (b) 5/10 (x)
United Arab Emirates 0 0 0
United Kingdom 0/15 (vv) 0 0