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Holding Companies Incentives – 01/2011

A Cyprus Holding Company can be effectively utilized for international tax planning purposes and at the same time enjoy the status of being located at a reputable business center within the European Union.

In summary, a Cyprus Holding Company offers the following advantages in relation to the major tax considerations:

  • Dividend income received from subsidiary companies abroad is exempt from taxation, provided the subsidiary company does not engage in more than 50% of its activities in producing investment income and the foreign tax burden on its income is substantially lower than that in Cyprus.

  • Double Tax Treaties with over 50 countries, enabling lower withholding tax rates on dividends or other income received from the subsidiaries abroad.

  • Being an EU Member State, holding companies registered in Cyprus may also enjoy no withholding tax on dividends received from EU subsidiaries as a result of the utilization of the EU Parent-Subsidiary Directive.

  • Profit arising from the disposal of shares is exempt from income tax

  • Full capital gains tax exemption on capital gains, except on the sale of immovable property situated in Cyprus.

  • No tax on capital gains or income on the liquidation of the Cyprus holding company.

  • No withholding tax on distribution of profits.

  • Outward dividends by the Cyprus holding company to its non-resident shareholders are exempt from any withholding taxes.

  • Profits earned from a permanent establishment abroad are fully exempt from Cypriot tax, subject to certain conditions.

  • A diversified group of Cyprus companies belonging to a Cyprus holding company can set off group relief for the utilization of tax losses.

  • No minimum holding period.

The above is brief and general in nature. Kindly contact our professionals for in-depth analysis and advice.

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