Cyprus economic substance.
Real. Demonstrable. Compliant.
OECD and EU requirements mean Cyprus companies must have genuine economic substance. We provide the local presence, directors, staff and infrastructure to meet substance requirements.
Qualified Cyprus-resident directors for your company board. Ensures management and control is exercised in Cyprus — the key residence test for Cyprus corporate tax purposes.
A Cyprus registered office address for your company — required for all Cyprus registered companies. Includes mail handling and forwarding.
Dedicated or hot-desk office space in Nicosia — for companies that need demonstrable physical presence in Cyprus.
Why substance matters for Cyprus companies
The OECD's Base Erosion and Profit Shifting (BEPS) project and the EU's Anti-Tax Avoidance Directives (ATAD 1 and 2) have significantly raised the bar for what constitutes a genuine Cyprus tax resident company. A company that is registered in Cyprus but managed from another country will not be treated as Cyprus-resident for tax purposes — and its income may be taxed in the country where it is actually managed.
The key test is management and control — where do the directors make real decisions? This means board meetings must be held in Cyprus, attended by Cyprus-based directors who genuinely exercise decision-making authority. Board minutes should reflect substantive discussions, not rubber-stamped resolutions.
Need substance for your Cyprus company?
Ask Taxerly about director services, registered offices and full substance packages.