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2023 Doing Business in Cyprus (India Edition)

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DOING BUSINESS C YPRUS<br />

86<br />

INDIA EDITION<br />

KEY FEATURES OF THE CYPRUS TAX SYSTEM<br />

Simple, transparent and EU harmonised tax system<br />

follow<strong>in</strong>g recommended OECD practices.<br />

Enjoys the tax benefits of EU Directives (Parent – Subsidiary<br />

Directive, Merger Directive and Interest and Royalties Directive).<br />

Extensive Tax Treaty network with 68 countries.<br />

A corporate <strong>in</strong>come tax rate of 12.5%, one of the lowest with<strong>in</strong> the<br />

EU with possibility to enjoy a much lower effective tax rate.<br />

Availability of a Notional Interest Deduction for<br />

companies receiv<strong>in</strong>g new equity fund<strong>in</strong>g.<br />

The tax deduction can reach up to 80% of the taxable<br />

<strong>in</strong>come generated by the new equity.<br />

IP Box regime based on the nexus approach which allows 80% deemed<br />

deduction on qualify<strong>in</strong>g profits from the bus<strong>in</strong>ess use of qualify<strong>in</strong>g IP.<br />

Increased deduction of 20% on the actual expenditure <strong>in</strong>curred for scientific<br />

research as well as research and development, subject to conditions.<br />

Attractive Tonnage Tax (TT) regime for ship owners, managers and charterers.<br />

Attractive tax jurisdiction for funds and attractive<br />

tax regime for fund managers.<br />

Capital ga<strong>in</strong>s are exempt from tax (except for capital ga<strong>in</strong>s aris<strong>in</strong>g<br />

from the disposal of immovable property located <strong>in</strong> <strong>Cyprus</strong>).<br />

Profits of a foreign Permanent Establishment exempt from tax.<br />

Ga<strong>in</strong>s from trad<strong>in</strong>g <strong>in</strong> securities (shares, bonds and certa<strong>in</strong><br />

other f<strong>in</strong>ancial <strong>in</strong>struments) are exempt from tax.<br />

Unilateral credit relief for foreign taxes.<br />

No withhold<strong>in</strong>g tax on dividend, <strong>in</strong>terest or royalty payments (for<br />

use of royalties outside of <strong>Cyprus</strong>) made abroad, unless these are<br />

made to EU blacklisted jurisdictions (relevant conditions apply).<br />

No taxes on entry and on qualify<strong>in</strong>g reorganisations.<br />

Carry forward of tax losses for five years.<br />

Tax <strong>in</strong>centives for expatriate employees tak<strong>in</strong>g up<br />

employment <strong>in</strong> <strong>Cyprus</strong> (20%/50% exemption).<br />

Dividend <strong>in</strong>come and <strong>in</strong>terest <strong>in</strong>come are exempt from SDC for non-domiciled<br />

<strong>in</strong>dividuals tak<strong>in</strong>g up tax residency <strong>in</strong> <strong>Cyprus</strong> (eligibility for 17 years).<br />

Possibility to obta<strong>in</strong> <strong>Cyprus</strong> tax residency by spend<strong>in</strong>g<br />

only 60 days <strong>in</strong> <strong>Cyprus</strong> (subject to conditions).<br />

No <strong>in</strong>heritance tax.<br />

No immovable property tax.

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