Article Amendments to the Cyprus Residency Programme

Revised Cyprus Permanent Residency

Pursuant to the provisions of Regulation 6(2) of the Aliens and Immigration Regulations, the Minister of Interior has decided to revise the current Permanent Residency programme with the new rules coming into force on 02/05/2023.

The revision includes updated restrictions and verification procedures with regards to the granting of an immigration permit.

The recent amendments are as follows:

A.    Investment Criteria

The applicant should make an investment of at least €300,000 in one of the following investment categories:

1.    Investment in a house/apartment: purchase should be from a land development company, which should concern a first sale of at least €300,000 (plus VAT).

2.    Investment in real estate (excluding houses/apartments): purchase of another form of real estate such as offices, shops, hotels or similar developments or a combination of these with a total value of €300,000. The properties in question may also be subject to resale.

3.    Investment in share capital of a Cypriot Company with activities and personnel in Cyprus: Initial investment in the share capital of a new company or increase of the share capital in an existing company registered in the Republic of Cyprus, which is based and operates in the Republic of Cyprus and has a proven physical presence in Cyprus and employs at least five (5) people.

4.    Investment in shares of a Cyprus Investment Organization for Collective Investments (type AIF, AIFLNP, RAIF): Investment in shares of a Cyprus Investment Organization for Collective Investments whose investments should be made in the Republic of Cyprus.

When investing in residential or other properties, the applicant must make a payment into the seller’s account at a Cypriot financial institution and prove that the contract of sale was filed with the Land Registry and provide official receipts of payment, regardless of the date of delivery of the property. It must also be proved that funds come from abroad and are not a product of internal borrowing. In cases where the applicant chooses to invest in a company’s share capital or in shares of an investment organisation, his total income or part of it may also arise from sources originating from activities within the Republic, provided that it is taxable in the Republic.

Additionally, the applicant, should prove that he/she has at his/her disposal a secured annual income of at least €50,000. The annual income is increased by €15,000 for the dependent spouse and €10,000 for each minor child, and dependent adult children up to the age of 25 years.

More specifically, when the applicant invests in a house or apartment, this income can be from salaries, pensions, stock dividends, fixed deposits or rents emanating from abroad, which will only be proven by the tax declarations from the country in which he/she is a tax resident. In calculating the total income, the income of the applicant’s spouse may also be taken into account.

B.    Quality Criteria

1.    Submission of a certificate of a clean criminal record from the country of origin as well as from the country of residence (if different), which should be provided on an annual basis.

2.    Submission of a valid health insurance cover which should be provided annually, if not registered with the national health scheme GHS.

3.    Certification that the applicant and his/her spouse do not intend to work in the Republic with the exception of being employed as Directors in a Company in which they have chosen to invest within the framework of this policy.

4.    In cases where the investment does not concern a Company’s share capital, the applicant and/or his spouse may be shareholders in Companies registered in the Republic and receive dividends. They may also hold the position of director in such companies without remuneration.

5.    Where an applicant chooses to invest in real estate, a company’s share capital or in shares of an investment organisation, he/she should present information about his/her residential place and that of his/her family members in the Republic.

In addition, applicants are required to prove on an annual basis that they continue to hold the investment and that they continue to receive the required annual income for themselves and their dependants.

An Immigration Permit may also be granted to the applicant’s children who are over 18 years old and are not financially dependent on the applicant, considering that an additional investment of €300,000 will be made for each adult child. Besides, each adult child should prove that they have at their disposal a secured annual income of at least €50,000 which is increased by €15,000 for a dependent spouse and by €10,000 for each dependent minor. However, permanent residency is no longer provided to the applicant’s parents and parents in-laws.

The application period takes approximately two months and the Cyprus Permanent Residency is indefinite, provided that the applicant and his/her dependents comply with their annual obligations.

Nobel Trust has a dedicated team of experts specializing in immigration services and can be of assistance in your relocation journey. For further information please contact us at [email protected] or call us at +357 22 022 777.

Regional or Global Headquartering in Cyprus

Regional or Global Headquartering in Cyprus

Cyprus is becoming increasingly popular as a country of choice by many international groups looking to relocate their headquarters. The country has drawn international attention and is becoming a top destination for doing business, investing and living. The benefits are multifaceted and attributed to the country’s status as a European Union and Eurozone member state with progressive legislation, regulatory regime, a stable financial environment with its advantageous tax system, and highly experienced professional service providers.

Corporate structuring is one of the country’s areas of expertise. Headquartering companies are established to channel investments into key global markets for many international companies that do business in Cyprus, the Eastern Mediterranean and even globally. With headquarters in Cyprus, companies enjoy free movement of goods, services, and capital.

As a leading jurisdiction for relocation and set up of regional headquarters, Cyprus offers an ideal location, with natural beauty, and strong history and culture, attracting human capital required to control and manage business activities.

Cyprus Tax system: tax advantages offered

  • Simple, transparent, and harmonized EU tax system
  • Tax benefits of EU directives
  • Cyprus double tax treaties with more than 60 countries
  • Notional Interest Deduction for companies receiving new equity financing which reduces significantly their taxable income
  • An Intellectual Property regime based on the Nexus approach and allowing an 80% imputed deduction on qualifying profits from the business use of qualifying intellectual property. Exemption of 4/5 of profits means that only about 20% of IP revenues are taxed at a corporate tax rate of 12.5%.
  • Attractive Cyprus tonnage tax (TT) scheme for shipowners, managers, and charterers
  • Attractive tax regime for Cyprus funds and for Cyprus fund managers
  • Capital gains are exempt from Cyprus taxation (excluding capital gains arising from the sale of immovable property located in Cyprus)
  • Profits of a foreign Permanent Establishment are exempt from tax
  • Securities trading proceeds (stocks, bonds, and certain other financial instruments) are exempt from Cyprus tax
  • Unilateral credit relief is granted to Cyprus companies for foreign taxes in Cyprus
  • No withholding tax on dividends paid by a Cyprus company, interest, or royalty payments (for use of royalties outside Cyprus) to its shareholders
  • There is no inheritance tax in Cyprus
  • There are multiple tax incentives and relieves for expatriates and individuals who seek to become tax resident in Cyprus
  • There is a friendly investor scheme for work-permits granted to non-EU employees of the employer company

Cyprus Foreign Investments

The traditional key driving forces of the country’s economy include traditional sectors of shipping, real estate, tourism and professional services. Over the last few years there is an increasing trend towards industries including energy, education, healthcare, and technology.

This latter industry is supporting the country in its transition from a global business centre to a growing technology and innovation hub. ICT companies can establish an IP holding and development company in Cyprus. The benefits include lower effective tax rates while having the legal protection applicable as per EU legislations, protocols and treaties. 

Tax incentive expenditure

TAX INCENTIVES FOR EXPENDITURE ON RESEARCH, DEVELOPMENT AND INNOVATION

On 18 May 2022, the government approved a tax deduction of 20% for legal entities and individuals investing in research, development and innovation, in a campaign to support the growth and competitiveness of Cyprus as a business and technology hub.

The tax deduction would be valid for three years, starting from tax year 2022. This is the second pillar of incentives followed by the incentives for headquartering being part of the scheme to attract foreign investments and businesses to Cyprus.

Following the recent geopolitical developments as well as other global factors, Cyprus has been experiencing an influx of high-tech and other companies which choose the island as a base for their operations or for relocating a part of those together with the respective human capital.

Cyprus is an emerging hi-tech jurisdiction, and such initiatives are likely to produce long term tangible results, assisting in both the island’s prosperity as well as that of the investors located here.