Considered pieces on the topics we work with every day. Not commentary, working knowledge, written for the people who need to act on it.
For a shareholder without Cyprus domicile, the Cyprus holding company sits on a different tax map. No dividend tax in, no capital gains tax on the disposal of shares out. What the 2026 reform changed was the corporate environment around it, not the foreign-shareholder position itself.
The 15% rate is the headline. At holding-company level it does not arrive in the form most readers expect. The reform that actually matters for the Cyprus holdco is the abolition of deemed dividend distribution, and how retained earnings now work.
A cross-border tax structure built on real Cyprus provisions, with every condition met. Why we declined the engagement, and what the case shows about how the firm reads the gap between what is legal and what is advisable.
The 183-day rule and the 60-day rule under the post-2026 reform, what residency does and does not give you, and the Tax Residency Certificate the Cyprus Tax Department issues for treaty positions abroad.
Who qualifies under Article 2(3) of the Special Defence Contribution Law, the two statutory routes for foreign nationals and Cyprus-origin individuals, what the exemption covers and what it does not.
The five-step application process for Cyprus Non-Dom status: Tax Identification Code registration, T.D.38 declaration forms, supporting documents, submission to the local district tax office, and the Non-Dom Certificate the Tax Department issues at the end.
How the deemed-domicile clock works in practice (residency for 17 of the previous 20 years), the 2026 EUR 250,000 investment-based extension option, the worked arithmetic, and what the individual needs to track each year.
Personal guarantees, floating charges, Euribor floors, debt service reserve accounts, dividend approval clauses, early repayment fees. The standard Cyprus business loan facility, what each clause was designed for, and the renegotiation entry points once the borrower's risk profile has improved.
The single-bank Cyprus relationship is no longer the only model. How a relationship composed across local banks, neobanks and payment institutions works, why local fees never retraced after rates normalised, and the renegotiation that follows once alternatives exist.
The Cyprus Notional Interest Deduction under Article 9B applies only to new equity, not debt. A thirteen-entity family office, consolidated and capitalised, shows the economics, the 80% cap, the anti-abuse limits, and when debt is still the right answer under the 15% corporate rate from 2026.
How much economic substance does a Cyprus company actually need? No single law defines it. Four overlapping frameworks, Unshell, CFC, CRS, DAC6, answer the same question from different directions. The minimum is rarely the right answer.
The client assumed someone was looking. The provider says the fee was never for looking. Both are right, and that is precisely the problem.
The application bundle for a CySEC licence is the constitutional document of the regulated entity. Once submitted and accepted, the gap between what those documents say the firm does and what it actually does is the primary measure of regulatory risk.
The standard question in a professional services acquisition is about revenue retention. It is usually the wrong question. The right question is about the two people the clients actually call.
A debit balance between a Cyprus company and its shareholders generates a deemed taxable benefit at 9% per annum through PAYE. In most companies where it exists, it has been building since year one.
A Cyprus buyer ran the model, did the sensitivity analysis, and found a strong deal. No one checked the building permits. One mezzanine changed everything.
In a family business sale, what blocks the deal is rarely the price. It is an unresolved feeling about fairness, asymmetric exposure, or unrecognised contribution that has not yet found a structure.
When siblings have unequal roles in a family business, the fairness question is unavoidable. The answer lies in separating two things that family wealth structures routinely conflate.
The tension between a founder and the next generation is real, predictable, and not unique. What resolves it is not a governance framework. It is the right sequence of conversations with the right people in the room.
Every law firm in Nicosia can help you establish one. Whether it provides genuine protection in the years that follow depends on decisions made after the trust deed is signed.
For Greek nationals living in Cyprus, the correct answer to the inheritance tax question is incomplete if it only covers the Cyprus side. Greek law follows Greek nationals and reaches their movable assets wherever located.
Most PIs and EMIs have a safeguarding arrangement in place. The supervisory question is whether it works as intended, continuously, under operational conditions.
CySEC Circular C418 defines the obligations that follow from the client account: the PSP/EMI rules, the two-sided reconciliation, signatory controls, the 20% group deposit limit, and the governance framework that surrounds all of them.
The internal audit function is the only CIF governance mechanism whose job is to find what is wrong. CySEC's inspection will ask the same questions, just without the opportunity to fix anything first.
Most Cyprus firms are worth less than their principals believe. The value is locked in the person, not the business. The exit window is the only time that changes.
The fit and proper assessment, the source of wealth examination, the substance check, and the activation phase. This is where most applications stall, not on capital.
The €75,000 figure in the law is the beginning of a conversation with CySEC, not the answer to it. The capital required is determined by the business plan.
A new CIF has no prior year financials. CySEC's assessment is based entirely on projections from the business plan. Your expense architecture determines your capital requirement.
Most applicants treat the business plan as a necessary obstacle. That misunderstanding has consequences that follow a firm for years after it receives its authorisation.
Every family governance engagement has one constant: governance itself. But governance is not one problem. It is four. And it does not have to start as the whole thing.
A buy-side due diligence story. The obligation existed. The provision did not. A guaranteed return is not inherently wrong. The question is what backs it.
A client we had worked with for years made a decision without us. We only noticed when our head of accounting saw the numbers.
The licensing decision should always begin with the operating model, not the licence. The most common mistake in CySEC licensing is selecting a structure on the basis of capital cost.
Four frameworks, four separate consequences, one failure point. A structure without genuine substance in Cyprus does not fail one of these tests. It fails all of them.
Article 21(2) of the Cyprus-Greece DTT allows the underlying corporate tax to be credited against Greek dividend tax. It is consistently either not claimed or actively argued against.
CRS has been exchanging data between Cyprus and Greece since 2017. The infrastructure for large-scale, data-driven cross-border audit is not being built. It has been built.
The environment has changed. Banks are not difficult, they are operating under a different risk calculus. Understanding that reframes the problem and changes what the correct response looks like.