Comparative Guides
Welcome to Mondaq Comparative Guides - your comparative global Q&A guide.
Our Comparative Guides provide an overview of some of the key points of law and practice and allow you to compare regulatory environments and laws across multiple jurisdictions.
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Results: 4 Answers
Corporate Tax
4.
Cross-border treatment
4.1
On what basis are non-resident corporate entities subject to tax in your jurisdiction?
 
Cyprus
Non-tax resident entities are subject to income tax in Cyprus on income from any business exercised through a permanent establishment in Cyprus and on certain income from sources within Cyprus (eg, rental income from property located in Cyprus or profits from the disposal of real estate in Cyprus).

For more information about this answer please contact: Charles Savva from C.Savva & Associates Ltd
4.2
What withholding or excise taxes apply to payments by corporate taxpayers to non-residents?
 
Cyprus
In general, Cyprus applies no withholding taxes on payments to non-residents, with the exception of income derived by non-residents from activities such as performances by public entertainers, technical assistance, oil and gas activities and film projections in Cyprus.

For more information about this answer please contact: Charles Savva from C.Savva & Associates Ltd
4.3
Do double or multilateral tax treaties override domestic tax treatments?
 
Cyprus
Yes, double or multilateral tax treaties override domestic tax treatments.

For more information about this answer please contact: Charles Savva from C.Savva & Associates Ltd
4.4
In the absence of treaties, is there unilateral relief or credits for foreign taxes?
 
Cyprus
Yes – in the absence of a treaty, Cyprus provides for a unilateral tax credit for any foreign taxes paid.

For more information about this answer please contact: Charles Savva from C.Savva & Associates Ltd
4.5
Do inbound corporate entities obtain a step-up in asset basis for tax purposes?
 
Cyprus
No.

For more information about this answer please contact: Charles Savva from C.Savva & Associates Ltd
4.6
Are there exit taxes (for disposed-of assets or companies changing residence)?
 
Cyprus
Currently there are no exit taxes for outbound entities. However, the full implementation of the EU Anti-Tax Avoidance Directive (expected by 1 January 2020) will introduce exit taxes.

For more information about this answer please contact: Charles Savva from C.Savva & Associates Ltd