Perspectives

Thinking from
the engagement floor.

Considered pieces on the topics we work with every day. Not commentary, working knowledge, written for the people who need to act on it.

Banking
What a Cyprus loan
actually asks for.

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.

Banking
Cyprus banking,
composed.

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.

Tax
Shareholder loan
or equity?

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.

Tax
How much presence
is enough?

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.

Business Advisory
Nobody is at fault.
Both sides are frustrated.

The client assumed someone was looking. The provider says the fee was never for looking. Both are right, and that is precisely the problem.

Licensing
The CySEC licensing documents
you approved without reading.

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.

M&A
You are not buying the revenue.
You are buying the two people holding it.

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.

Tax
The company lent you money.
The taxman calls it income.

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.

M&A
The model was solid.
The permits were not.

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.

Family Advisory · M&A
The number is rarely what kills the deal.
The feeling is.

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.

Family Advisory
Inheritance is for all.
Reward is for those who work.

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.

Family Advisory
The father built everything.
The son wants to change it. What actually helps.

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.

Family Advisory
Setting up a Cyprus International Trust
is the easy part.

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.

Tax · Advisory
Cyprus has no inheritance tax.
That is not the complete answer.

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.

Licensing
The safeguarding obligation does not end when you open a segregated account.
It begins there.

Most PIs and EMIs have a safeguarding arrangement in place. The supervisory question is whether it works as intended, continuously, under operational conditions.

Licensing
Having a client account satisfies one of CySEC's requirements for client fund segregation.
C418 defines what comes after.

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.

Licensing
The internal audit is not a compliance obligation.
It is a dry run.

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.

Family Advisory · M&A
The value of your firm is not what you built.
It is what survives without you.

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.

Licensing
CySEC is not reviewing your application.
It is reviewing you.

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.

Licensing
The CIF minimum capital requirement:
what the law says and what CySEC actually asks for.

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.

Licensing
Capital adequacy in Year One:
why your expense architecture is the assessment.

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.

Licensing
The business plan you submit to CySEC
is not a document. It is a commitment.

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.

Family Advisory
You have the estate.
Now comes the harder part.

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.

M&A
The Guarantee
That Wasn't.

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.

Business Advisory
Growth plans are written by optimists.
The runway is shorter than the plan says.

A client we had worked with for years made a decision without us. We only noticed when our head of accounting saw the numbers.

Licensing
CySEC licensing: AIFM, CIF
and the operating model question.

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.

Tax
Part 2 of 3
The structure is still standing.
Is it still working?

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.

Tax
Part 3 of 3
The credit that nobody claimed.
It has been in the treaty since 1968.

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.

Tax
Part 1 of 3
The Cyprus structure your client set up
hasn't changed. Everything around it has.

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.

Banking
Banking is not a given.
Treat it as a risk.

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.