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