The term “economic substance” refers to the actual financial and operational activities of corporate structures. Foreign investors who register a company in Cyprus are required to demonstrate enough substance in the local jurisdiction to prove that they are based in the country for reasons other than tax avoidance.

Therefore, establishing substance in Cyprus is important for foreign investors to avoid potential disputes with foreign tax authorities looking to challenge the tax residency status of the Cyprus company. Furthermore, Central Bank of Cyprus indicated that the lack of substance might prevent legal persons from opening bank accounts in the country.

How to establish economic substance in Cyprus

Cyprus companies need to demonstrate an economic purpose and relevant infrastructure depending on the circumstances of the organization. Examples include:

• Maintaining an office in Cyprus suitable for the size and the business of the company
• The majority of Directors should be residents of Cyprus
• Holding shareholder and director meetings in Cyprus
• Exercising effective management and control of the company in Cyprus
• Signing of agreements in Cyprus
• Have contact details such as telephone line, email, fax and website
• Maintaining corporate bank account with a local bank
• Bank account signatories based in Cyprus
• Employing or appointing qualified directors and/or employees
• Company employees to pay social insurance contributions
• Accounting records to be maintained in Cyprus
• Annual Financial Statements to be audited by Cyprus licensed auditors

Our services include:

• Review the proposed structure to identify tax risks
• Advice and recommendations on implementing substance
• Assistance to rent suitable office space
• Assistance for the employment of qualified directors and employees
• Assistance to rent accommodation for foreign staff
• Opening of a corporate bank account in Cyprus
• Payroll services and Social Insurance and annual tax compliance
• Organizing board of directors and shareholders meetings in Cyprus
• Audit, Tax and VAT services