Especially if you travel to eastern Europe (places such as Latvia) you’ll hear a lot within the offshore company formation circles about Cyprus companies, they are fairly common there. (As you travel the world you’ll find there are popular spots or favored tax havens in many of the countries of the world Barbados for Canada (though this is an outdated view), Puerto Rico for the US, etc.) Frankly, I have no idea why it’s become popular for anyone as I loathe Cyprus when compared with the alternatives.
Let’s start with what’s supposedly good about Cyprus:
- It’s part of Europe
- Relatively low taxes – 12.5% sticker rate is one of the lowest in Europe
- A reasonable network of tax treaties
- Non-resident companies are available – opening up the possibility of 0% tax companies
- No dividend withholding taxes
So you might ask with all those advantages what’s not to love?
The reality is Cyprus is an option, it’s just a worse option than some of the available alternatives, most specifically Gibraltar. Let’s compare:
- Both are part of Europe so neither scores any points over the other
- Company formation in Cyprus is around 2250 EUR, while Gibraltar is around 850 GBP making Gibraltar cheaper
- Both can have non-resident companies but Cyprus non-resident companies are still subject to annual audited financial statement requirements when even resident Gibraltar companies aren’t up to an annual income of 5 million GBP and non-resident companies don’t have to file a return at all making Gibraltar companies much less expensive to maintain
- Cyprus definitely has an advantage when it comes to its network of tax treaties and I’ve heard it argued that “you should have your Cyprus company tax resident in Cyprus in order to tax advantage of the treaties” but in practice I rarely find there is any advantage in doing so, if you’re doing offshore tax structuring that would result in a Cyprus company you typically aren’t looking for the benefits of tax treaties anyway
- Cyprus laws etc. are all in Greek making it much more of a hassle for those more familiar with English to obtain information and do business there
- Cyprus isn’t a particularly confidential jurisdiction
- While there is very accessible local banking available in Cyprus and not in Gibraltar, a Gibraltar company could easily open a Cyprus bank account but who would want to given their history of financial instability?
- Gibraltar has a 10% tax rate on corporations while Cyprus has a 12.5% tax rate making Gibraltar more favorable in raw tax rate on resident companies
- Cyprus taxes on worldwide income while Gibraltar has a quasi-territorial tax system making Gibraltar even more tax competitive for resident companies
If you’re going to have a resident local company then yes, Cyprus does have one of the lowest tax rates in Europe combined with a mediocre network of tax treaties. Whether there is any reason to go there rather than say Latvia or Estonia or Malta is a question of the individual circumstances of your business but as a general rule it is a rare day that forming a company in Cyprus makes sense for a non-resident.
Bottom line I almost never use nor recommend Cyprus as a jurisdiction to form an offshore company.