An EU holding platform
Holding Company Structures in Cyprus
Cyprus combines an EU seat, an exemption for dividends received and no withholding on distributions out.
GCC business setup specialists
The combination is what makes it work
Few jurisdictions offer all of: membership of the European Union and therefore directive access, a general exemption for dividends received from subsidiaries, exemption from tax on gains on disposals of securities, an extensive treaty network, and no withholding tax on dividends paid to shareholders anywhere. Cyprus does. The condition attaching to every one of those is that the company is genuinely resident and managed here.
- Each exemption tested against its actual conditions
- Substance requirements set out in writing before you commit
- Honest about the anti-abuse tests the structure must pass
20+
Mainland, free zone and offshore jurisdictions we file in — so the recommendation is based on your activity, not on which authority we happen to be registered with.
7,000+
Companies successfully established.
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What it offers
The Cyprus holding company, feature by feature
Every item has a condition.
| Feature | Position |
|---|---|
| Dividends received | Generally exempt, subject to conditions. |
| Gains on securities | Generally exempt from tax. |
| Dividends paid to shareholders | No withholding to non-residents. |
| EU directive access | Available as a member state entity. |
| Treaty network | Extensive, where residence is established. |
| Anti-abuse tests | Apply; substance is required. |
Exemptions, their conditions, directive access and EU anti-abuse measures are set by law and amended, and treatment in the subsidiary’s and shareholder’s countries also applies. Cyprus is a European Union member state, so EU directives, the single market and EU anti-avoidance measures all apply.
How it works
Setting the structure up
Substance is designed in from the start.
01
Map the group
Where the subsidiaries are, where the shareholders are, and what flows are expected in each direction.
02
Test the exemptions
Whether the dividends received exemption and the securities exemption actually apply on your facts, rather than relying on the headline.
03
Incorporate with substance
Company formed with a board that will genuinely manage it here, and substance arrangements implemented from the outset.
- Group structure chart
- Where each subsidiary is resident
- What the subsidiaries do
- Expected dividend flows up
- Whether disposals of subsidiaries are contemplated
- Where the ultimate shareholders are resident
- Whether directive access is relevant
- Whether treaty relief will be claimed
- Proposed directors and their residence
- Where board meetings will be held
- What substance will be maintained
- Advice already received elsewhere
Scope
What is included, and what is not
Stated plainly, so nothing is added once the engagement starts.
Included in the service fee
- Structure recommendation against your group
- Exemptions tested against their conditions
- Substance requirements set out in writing
- Incorporation and share structure
- Company secretary and registered office
- Tax, VAT and beneficial ownership registrations
- Share transfer documentation
- Annual compliance and audit calendar
Not included, quoted separately
- Registry fees, paid at cost
- Audit fees
- Tax advice in subsidiary or shareholder jurisdictions
- Formal opinions on treaty or directive access
- Resident director services unless quoted
- Substance costs such as office and staff
- Valuations
- Transfer pricing studies
Verify independently
Official Cypriot authorities
We file directly with these bodies on your behalf.
Central Bank of CyprusDepartment of Registrar of Companies and Intellectual PropertyTax DepartmentCyprus Securities and Exchange CommissionCommercial banks and their compliance functionsBeneficial ownership register
Questions
Cyprus holding structures — FAQs
Why is Cyprus used for holding companies?
Because it combines EU membership and directive access, an exemption for dividends received, exemption on gains from securities, a treaty network and no withholding on distributions out.
Are the exemptions automatic?
No. Each has conditions, and we test them against your actual subsidiaries rather than assuming the headline applies.
How is Cyprus different from the United Kingdom here?
The United Kingdom lost access to the EU directives on leaving the Union. Cyprus retains it, which matters for intra-European flows.
How is it different from an offshore holding company?
Cyprus is inside the EU with a real tax system, which makes it more credible with banks and counterparties — and also subject to EU anti-abuse rules requiring genuine substance.
What happens if substance is thin?
Anti-abuse tests, treaty denial, banking refusal, or all three. The structure only works if the company is genuinely managed here.
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