Company Re-domiciliation in Cyprus

Unlock unparalleled advantages by transforming your foreign company into a "tax resident" of Cyprus. Embrace the strategic move to Cyprus, where you can harness the perks of a favorable tax regime, including a mere 12.5% corporate tax rate, dividend exemptions, and numerous deductions. Cyprus, standing among jurisdictions allowing seamless "re-domiciliation," facilitates the transfer of a company's "seat of incorporation" into or out of its jurisdiction. This streamlined process, governed by the amended Companies Law Cap. 113, presents a game-changing opportunity for international investors, enabling foreign companies to become tax residents of Cyprus and leverage its advantageous tax features.

The Key Advantages Include:

  1. Lowest Corporate Tax Rate in Europe - 12.5%
  2. Tax-Exempt Dividend Income (Subject to Non-Stringent Conditions)
  3. No Withholding Taxes on Payments of Dividends, Interest, and Royalties Irrespective of Recipient
  4. No Taxation on Profits from the Sale of Securities (No Minimum Holding Period, Percentage, etc.)
  5. No Taxation on Profits of Foreign Permanent Establishments
  6. No Taxation on the Liquidation of a Cypriot Company
  7. Wide Tax Treaty Network
  8. Unilateral Tax Credit Relief Irrespective of the Existence of a Tax Treaty
  9. No Substance, Debt-Equity, and Thin Capitalization Rules
  10. Full Adoption of the EC Directives and Many More

This unique opportunity allows foreign companies to tap into the success of the Cypriot tax regime without the need for extensive restructuring. By avoiding a complete transfer of assets and liabilities to a newly incorporated Cyprus company, businesses can seamlessly transition, maintaining continuity and realizing significant savings in administration and other costs.

Application for Re-domiciliation
Foreign companies, meeting specific criteria, can apply for re-domiciliation to the Registrar of Companies in Cyprus. The process involves appointing a local representative, preparing an application (form "ME 1"), and submitting necessary documents. The straightforward and expedient process ensures a smooth transition, allowing the foreign company to obtain a temporary certificate of continuity upon approval.

Documents Required
Accompanying documents include a resolution authorizing re-domiciliation, amended Memorandum and Articles of Association, certificate of good standing, document ME (A), affidavit confirming financial standing, a list of company officials, and evidence of re-domiciliation approval from the country of origin.

Licensed Activities and Public Companies
For companies engaged in licensed activities or functioning as public companies, additional documentation may be required, ensuring compliance with regulations.

Registration in Cyprus
Upon provisional registration by the Registrar, the foreign company gains temporary legal entity status in Cyprus. Compliance with the issuance of a temporary registration certificate and submission of required evidence within six months solidifies the re-domiciliation, culminating in the issuance of the certificate of continuity.

Seize this transformative opportunity to re-domicile your business to Cyprus, where a world of tax benefits and operational continuity awaits. Elevate your enterprise to new heights by embracing the strategic advantages of the Cypriot tax jurisdiction.

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