News and developments
Important Tax Amendments – December 2021
As per current law a Cyprus company is considered as Cyprus tax resident if the management and control is exercised in Cyprus. With, the new law, and the introduction of the incorporation test, if a Cyprus company is not managed and controlled in Cyprus and is not tax resident of another country it will be considered as tax resident of Cyprus as it was incorporated in Cyprus. This will apply from 31 December 2022.
Withholding tax payments of dividends, interest and royalties from Cyprus companies to companies resident or registered in jurisdictions included in the EU list of non-cooperative jurisdictions on tax matters
On the same date as above and applying from 31st December 2022 as well, another law was approved whereby 17% withholding tax will apply If a Cyprus tax resident company pays dividends to :- a company which is a resident in a jurisdiction that is included on the EU List of non-cooperative jurisdictions on tax matters (black list see link: https://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/) ,
- or to a company incorporated or registered in a jurisdiction included on the EU Black List and not considered to be tax resident in another jurisdiction which is not included on the EU Black List,
- paid or credited to a company which is resident in a jurisdiction included on the EU List as above,
- or to a company which is incorporated or registered in a jurisdiction included on the EU List and is not resident in another jurisdiction that is not included on the EU List.
- to a company of a jurisdiction included on the EU List (see link above),
- or to a company which is incorporated or registered in a jurisdiction included on the EU List and is not resident in another jurisdiction that is not included on the EU List,