Choose the right Cyprus vehicle: trading, holding, IP, branch or moving your company here.

For most groups, yes. The rate rise to 15% does not touch dividends received or gains on shares, which stay exempt, and Cyprus still withholds nothing on dividends paid out. The reform also removed the deemed dividend charge and stamp duty. It is worth less where subsidiaries are passive and low-taxed, or where the owners live in a country that taxes the dividends anyway.

Normally no. Dividends are exempt from corporation tax unless the paying company could deduct them. They are also exempt from the Special Defence Contribution unless the payer is mainly passive and taxed below 7.5%. Cyprus has no minimum shareholding or holding period for this.

Only when both tests fail: more than half of the paying company's activities produce investment income, and its foreign tax burden is below 7.5%, which is half the Cyprus rate. Then 5% applies, down from 17% before 2026, with credit for foreign tax withheld on the dividend.

No, with one exception. Dividends paid to associated companies in EU-listed jurisdictions carry 17%, and to associated companies in low-tax jurisdictions 5% from 2026. Dividends to individuals abroad and to companies in normal-tax countries carry no Cyprus withholding tax.

Since 17 February 2026: American Samoa, Anguilla, Guam, Palau, Panama, Russia, Turks and Caicos, the US Virgin Islands, Vanuatu and Viet Nam. Cyprus applies its measures where a jurisdiction is listed at the time of payment and was listed in the previous calendar year, so the two February additions may only come into scope in 2027. The list is reviewed every February and October.

Under Cyprus law, yes: from 2026 incorporation in Cyprus is enough. But if the other country also treats it as resident because decisions are taken there, the treaty tie-breaker usually hands residence to the place of effective management. A Cyprus company run from Berlin is likely to end up German resident for treaty purposes.

A branch is quicker and suits a trial or a single project. It pays 15% on Cyprus profit and can send profit home tax free, but it cannot use Cyprus treaties or the EU directives and offers no liability shield. A subsidiary costs more to run and must be audited, but it is a separate EU company in its own right.

Yes, if your current country allows companies to leave and the company's form matches a Cyprus company. Cyprus law lets a foreign company continue here as the same legal person, keeping its contracts and history. From 2026 its assets enter Cyprus at market value for tax, whether it comes from the EU or elsewhere. Your current country may charge exit tax.

Only if the holding company controls a foreign company that pays less than half the tax it would pay in Cyprus, and that company's income comes from arrangements that are not genuine. Small companies with accounting profit under €750,000 and non-trading income under €75,000 are outside the rules. Trading subsidiaries with their own people are rarely affected.

Yes. The reform kept it, and the Tax Department published the 2026 reference bond yields in March 2026. It gives a deduction on new equity used in the business, capped at 80% of the taxable profit that equity produces. At 15% it is worth a fifth more per euro than at 12.5%.

Gains on shares, bonds and similar securities are exempt for companies and individuals, with no holding period. The exception is shares in companies whose value comes from property in Cyprus. From 2026 that test applies at 20% of value, down from 50%, and the gain attributable to the property is taxed at 20% capital gains tax.

No Special Defence Contribution, and no income tax on the dividend. The only charge is the General Healthcare System at 2.65%, on total income up to €180,000 a year, so it stops at €4,770. Non-dom status lasts 17 of the last 20 years of residence, with a paid extension available.

Enough that a tax inspector in the subsidiary's country would accept that Cyprus is where decisions are made. In practice that means Cyprus resident directors who decide, board meetings here, a Cyprus bank account and costs that match the activity. A pure holding company needs far less than a trading or IP company, but never nothing.

Not always. If you do not live in Cyprus and will not put people here, a Cyprus company is likely to be treated as resident where you run it. Cyprus earns its place when you or your team relocate, when you hold EU subsidiaries, or when its treaties cut withholding tax on what you receive.