+357 24 000215 (Cyprus)

+7 (926) 920-55-51 (Moscow)

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Cyprus company formation

We work in Cyprus sice 2005


  • Full member of the European Union.
  • Legal system structured on the English counterpart largely following English case law and the statutes regulating business matters and procedures.
  • Well regulated financial environment - international clients can incorporate Cyprus Companies and place the shares of such Companies into trusts.
  • Corporation tax rate of 12.5% (flat rate) - one of the lowest mainstream rates of tax on Corporate profits within EU.
  • Exemption from tax on profits of foreign permanent establishments (PE) provided that more than 50% of the income of the PE derives from trading activities or the foreign tax burden on the income of the PE is not substantially lower than the tax burden of the Cypriot resident Company.
  • Profits generated from transactions in shares, bonds and other qualifying securities are exempt.

  • No withholding taxes on interest and royalty payments to non-residents (Company or Individual).
  • Flexible reorganisation rules and group relief provisions.
  • Tax losses are carried forward for a period of five years.
  • Tax credit for taxes paid abroad is given unilaterally irrespective of the existence of a double tax treaty.
  • Flexible re-domiciliation laws in and out of Cyprus without disturbing the overall structure.
  • Notional Interest Deduction (NID) on new equity introduced as from 2015 onwards effectively replacing the back to back financing arrangements which were taxed at the minimum acceptable margin of 0.35%. (See NID Leaflet).

  • No Thin Capitalisation rules.
  • Access to EU Parent/Subsidiary directive.
  • Exemption on foreign source dividends (in most cases) paid by a foreign subsidiary to a Cyprus Holding Company.
  • Exemption on capital gains realised from sale of non-Cyprus assets (i.e. real estate, foreign share capital).
  • No Controlled Foreign Company (CFC) rules, thus exempting foreign income received even if that income received from tax heaven country or in respect of passive activities.
  • No withholding taxes on dividend distribution to foreign non-resident shareholders (Company or Individual).

  • Distribution of assets without taxation to non-resident shareholders on Liquidation.
  • Purely holding Companies outside scope of VAT in Cyprus.
  • Cyprus has signed double tax treaties with over 50 countries most of them being based on the OECD Model Convention.
  • The new Cyprus IP regime allows for 80% of qualifying profits generated from qualifying assets to be deemed as tax deductible expenses. In calculating this, the level of qualifying profits is positively correlated to the extent the claimant performs R&D activities to develop the relevant asset. Qualifying assets include amongst others patents and copyrighted software programs but do not include trademarks and copyrights.

Company formation in Cyprus

The prices are without VAT (19%) and are intended for professional intermediaries only.


1790 €


5.000 EUR share capital




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Cyprus companies: how they are exploited now

There are many reasons why entrepreneurs used to settle Cyprus companies. But nowadays one should be very careful applying old schemes. Still there are several variants how Cyprus companies can be used for tax planning.

Investors Scheme

Permanent Residency Scheme and Citizenship Scheme

Corporate Relocation Services



As with any tax planning exercise, before we move on to consider the tax considerations at the country of destination, the tax implications in the country of origin of the HNWI need to be considered. In brief, the same could be summarized as follows:

1) Do any exit taxes apply?

2) Do recapture rules apply to any income realised after migration?

3) Are there any specific tax rules to retain individuals?

4) Are there any reporting obligations?

All the above will have to be examined in the country of origin by the individual willing to migrate to another country preferably with the assistance of a tax consultant. As regards Cyprus, any person who has relocated in Cyprus and subsequently, for any reason wants to leave Cyprus will not have to pay any exit taxes and no recapturing rules will apply, making exit from Cyprus easy and effective.


Moving on to the country of destination, the following considerations should inter alia be considered:

1) What are the tax residence criteria under domestic tax laws?

2) What are the available methods to avoid taxation in case of dual residence?

3) What are the main types of personal taxes applicable to individuals in the country of destination?

4) Are there any specific tax rules to attract individuals such as special regimes for new residents, tax holidays etc?

5) How is the profit from investments, including dividends, interest, capital gains and rental income taxed?

6) Do any wealth or succession taxes exist?

7) Are there any wealth structuring tools in the country of destination?

8) Are there any reporting obligations as well as voluntary disclosure programs and what are the mechanism available to tax authorities for the exchange of information?

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General partner of the company
Vita Liberta Limited
Konon Sergey

Professional experience

  • 2005-2012: OJSC “Promsvyazbank” Cyprus branch, from bottom position to the Head of business development department (responsible for cooperation with corporate clients).
  • 2012-2016: Bank of Asia, Russia, Vice President of international Business (responsible for the development of two departments: international correspondent banking department and international corporate clients’ department).

  • 2016 - present - founder and General partner of Vita Limirta Limited company.

Excerpt from the speech of Mr. Konon Sergey at the IV-th annual conference "Practice of international tax planning. Actual issues ", 2011.

Mobile: +7 (926) 920 55 51

Cyprus office: +357 24 000215

Moscow office: +7 (495) 545 90 98

Telegram/what's up/viber: +7(929)9081047

Skype: ygrtima


The information contained in this web page is intended as a guide only and every reasonable effort was made to ensure the accuracy and timeliness of the information.

In no circumstances shall we be legally bound by any information contained in this document, and we shall accept no liability in respect of loss caused by reliance on such information.