EU holding location
English-influenced company law, EU IBAN, established holding structures.
Cyprus is an EU location with English-influenced company law. With the 2026 tax reform (in force since 1 January 2026), corporate tax rose from 12.5 % to 15 %; several rules were modernised at the same time. Economic substance is required for tax recognition (ATAD-3). Legal status: 2026, without guarantee.
English-influenced company law, EU IBAN, established holding structures.
0 % SDC on dividends and interest for 17 years; only 2.65 % GeSY (capped).
2026 reform: loss carry-forward 7 years, 20 % R&D super-deduction, stamp duty abolished.
| Germany | Cyprus | |
|---|---|---|
| Corporate tax | ~30 % (effective) | 15 % (since 2026) |
| Tax on €100,000 profit | ~€30,000 | €15,000 |
| Dividends to shareholders | 25 % withholding tax (+ surcharge) | 0 % SDC with non-dom status |
Real substance on the ground is required for tax recognition (office, management, activity — ATAD-3).
| Legal form | Minimum capital | Shareholders | Typical use |
|---|---|---|---|
| Private LTD | none prescribed | 1–50 | Standard, holding, trading, IP |
| Public LTD (PLC) | approx. €25,629 | ≥ 7 | Listed/capital-market oriented |
| VCIC | fund-dependent (CySEC licence) | — | Investment funds |
| Partnerships (GP/LP/LLP) | none | ≥ 1–2 | Cooperations, investment |
| Branch / Trust (CIT) | — | — | Market entry / asset structuring |
Mandatory: registered office and company secretary in Cyprus; annual audit by licensed auditors; UBO registration.
Define the target structure and substance needs.
Reserve the company name, prepare documents.
Registrar of Companies; appoint the secretary.
Open an EU IBAN, register for tax.
Real business premises and activity on the ground.
Apply for residency and non-dom status.
Registration takes about 1–2 weeks.
Registration, secretary and registered office, annual audit; office (substance) ~€200–600/month depending on location (indicative).
| Item | Rate |
|---|---|
| Corporate tax | 15 % (since 1 Jan 2026; previously 12.5 %) |
| SDC dividends (non-dom) | 0 % (17 years) |
| SDC dividends (domiciled residents) | 5 % (previously 17 %) |
| GeSY (health contribution) | 2.65 % (capped) |
| Loss carry-forward | 7 years (previously 5) |
| R&D super-deduction | 20 % (2025–2030) |
2026 reform: deemed dividend distribution (DDD) abolished for profits from 2026; stamp duty abolished.
Tax residency via the 183-day or the 60-day rule; non-dom status for persons not domiciled in Cyprus (0 % SDC on dividends/interest). For those leaving Germany: exit taxation and extended limited tax liability (AStG) plus real substance need to be considered.
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15 %.
0 % (17 years).
7 years.
| Metric | Value |
|---|---|
| New companies 2025 | 18,858 (+26.5 % vs. 2024) |
| Corporate tax | 15 % (from 2026) |
| Non-dom advantage | 0 % SDC on dividends, 17 years |
15 % since 2026 (previously 12.5 %).
0 % SDC on dividends/interest for 17 years, only 2.65 % GeSY.
Yes – office, management and activity on the ground (ATAD-3).
Yes, annually by licensed auditors.
Company formation
Company formation
Company formation
This page is for general information only and does not replace legal or tax advice. Binding information is provided by the competent authorities of the respective country and by lawyers, notaries and tax advisors licensed there. For the tax consequences of relocating from Germany or Austria, tax advisors licensed in those countries are responsible. All information without guarantee. Status: July 2026. For an individual assessment: contact@goglobal.associates.
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