Cyprus tax for Russian nationals.
Non-dom. Structures. Planning.
Cyprus has a large Russian-speaking community and a long history of Russian-owned corporate structures. Here's the current tax picture for Russian nationals and residents moving to or operating through Cyprus.
Russia suspended the double tax treaty with Cyprus in August 2023. Russian-source income is no longer protected by treaty rates — withholding taxes apply at Russian domestic rates.
Non-dom status in Cyprus is fully available to Russian nationals who establish Cyprus tax residency. The SDC exemption applies regardless of DTT status.
Russian nationals can open Cyprus corporate accounts subject to enhanced due diligence. EU-licensed EMIs and some specialist banks remain accessible for properly structured entities.
Russia-Cyprus tax treaty suspension — what it means
Russia unilaterally suspended the double tax treaty with Cyprus (and several other jurisdictions) in August 2023. This means that Russian-source income — including dividends from Russian companies and interest from Russian sources — is no longer covered by preferential treaty rates. Russian withholding taxes now apply at full domestic rates.
For Russian nationals who have already relocated to Cyprus and hold assets outside Russia, the impact is limited. Non-dom status, Cyprus corporate structures and the broader Cyprus tax regime remain fully available and effective. For those with significant Russian-source income, specialist restructuring advice is strongly recommended.
The legal and tax position for Russian nationals operating international structures has changed significantly since 2022. Sanctions compliance, CFC reporting obligations in Russia and the treaty suspension all require careful legal and tax advice specific to your individual situation. This page provides general information only. We strongly recommend a consultation before making any structural changes.
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