| Jurisdiction Special Focus: Cyprus
by the Investors Offshore Editorial Team, January
2012
IMPORTANT WARNING:
The contents of this report have been compiled in good faith by Investorsoffshore.com
to provide assistance to investors, but do not constitute investment advice
or recommendations. Investors should not rely upon the information given
in order to choose types or routes of investment but should make their
own independent enquiries before making choices. Investorsoffshore.com
has taken reasonable care in researching and presenting the information
herein but makes no representations as to its accuracy and accepts no
liability for actions taken or not taken as a result.
Introduction To Cyprus
Cyprus is an independent sovereign republic in the Eastern Mediterranean,
with a population of 1.1m (July 2011 est), of whom the majority are ethnically
Greek, living in the southern part of the island. More than 200,000 Turkish
Cypriots and Turkish immigrants live in the northern part of the island,
separated from the south by a UN-supervised buffer zone. The official
languages in the two zones are Greek and Turkish, but many Cypriots speak
English, which is extensively used in business and commerce.
Cyprus is the third largest island in the Mediterranean after Sicily
and Sardinia, and has hot dry summers and mild winters. The favourable
climate means that a wealth of activities such as sailing (about which
more later…), cycling, golf and skiing in the winter are popular
with residents and expats alike.
The main cities are Nicosia (the capital and business centre, itself
divided by the UN 'green line'), Limassol, Paphos and Larnaca, these last
three being coastal cities around which the important tourist industry
is concentrated. There are international airports at Larnaca and Paphos,
where British immigrants are concentrated. There is a strong Russian community
in Limassol.
Cyprus joined the European Union in 2004, although the 'acquis communautaire'
is suspended in the northern part of the country.
The Divided Island
Cyprus was a Venetian satrapy in the late Middle Ages, but belonged to
the Ottoman Empire in the 15th to 19th centuries. From 1878 onwards the
island was administered by the British, becoming a colony in 1925. An
independence movement led to the creation of a separate Cypriot republic
in 1960, but attempts to unify Cyprus with Greece antagonized the Turks,
who invaded the island in 1974, leading to the present divided island.
UN troops have remained in the country since 1974 to uphold the truce
between the two sides. Whilst restrictions on movement and trade over
the demarcation line were lifted following Cyprus's entry into the European
Union, it is uncertain when the island will become fully integrated.
Multiple attempts to re-unify the island as a 'bicommunal federation'
have failed, most notably the 'Annan' plan in 2004, which was rejected
by a high proportion of Greek Cypriots. The root problem is the existence
of a large refugee population of Greek Cypriots who lost their homes and
land when they were expelled from the north by the Turks. Talks between
the two sides under the aegis of the UN have been ongoing for years, but
the parties occupy very entrenched positions, and as of 2012 it would
be a very optimistic person who expected a resolution in the near future.
As time goes by, it becomes more and more likely that there will be a
permanent partition of the island. Absent a solution, the EU and the US
will have to lean on the Greek Cypriot government very heavily if it is
not to stand in the way of Turkey's EU accession process. The political
future of the island is therefore somewhat unclear.
The Culture Of Cyprus
The island's location has ensured that it played a full part in Mediterranean
history, and its essentially Greek culture is leavened with many other
influences. Classical ruins abound, but the most important modern influence
has probably been that of the British, whose stay has contributed substantially
to the island's Western business environment.
In the South, the currency is the Euro, whereas in the self-styled 'Turkish
Republic of Northern Cyprus' (recognized by very few of the international
powers other than Turkey), the currency is the Turkish Lira.
The cost of living in Cyprus is reasonable, although there are quite
large differences between the north and south due in part to the collapse
of the Turkish Lira in early 2001. Compared to the cost of living in Western
Europe Southern Cyprus is moderately inexpensive, whereas compared to
the Middle East, it is reasonably pricey.
Local newspapers are published in English and Russian, besides of course
Greek and Turkish. Radio and television programmes are broadcast in English
by the British forces, who retain two large military bases on the island.
The local broadcasting authority, CYTA, relays many international television
programmes.
The Cyprus Property Sector
Although Cyprus may well be an appropriate location for holding international
assets (dealt with below), most incoming investors are interested in Cyprus
as a possible home or for 'buy-to-let' investment. There are very many
English-speaking developers and estate agents who offer newly-completed
or 'off-the-plan' apartments or houses at all levels of the market. Until
2008 there was also a thriving 're-sale' market. Cyprus saw a boom in
land and building prices during the years that followed EU accession,
with values doubling or even trebling by 2008, when the market paused
before tumbling in 2009. Prices are currently about 25-30% off their peak,
but there has not yet been a surge in repossessions, probably due to the
reluctance of the banks to write off bad loans.
There is a considerable overhang of unsold and uncompleted properties,
so that a determined buyer can find very good bargains. Some warnings
are in order, however, of which the most important relates to title deeds.
These are not automatically issued for newly-built properties in Cyprus;
instead it may take up to five or more years for the bureaucracy to issue
a deed, and if the bank has lent to a developer who has split up a plot
to build houses or apartments, then the title deeds will not pass to the
eventual buyer until the bank has been paid off, making re-sale problematic.
Lawyers have not been good at advising clients about this problem. There
is now much greater awareness of the title deed issue, and under pressure
from the EU and the UK, the government is finally and very reluctantly
putting new legislation into place, and the remaining two parts of the
'town planning amnesty' bill were approved by the Cypriot parliament in
April 2011. However, a careful buyer will make sure that all necessary
title searches have been done, and that for a re-sale, the deed is available.
Whilst there are no hard and fast rules governing the purchase method
of property in Cyprus, one will typically buy through an agent or developer,
or a partnership of both. Agents typically charge the buyer a commission
of 5%, although an extra 3% may be charged if a developer is also involved.
However, fees have become more negotiable as the market has cooled. There
is nothing to stop a buyer dealing directly with a seller, but this is
not recommended as the land registry system is somewhat bureaucratic and
best tackled by a professional representative.
Legal fees are likely to be in the region of EUR1,200 for a normal transaction.
Obtaining finance for a property purchased in Cyprus was reasonably straightforward
until 2009, when the banks became more cautious. Thanks to the country's
British connections, most bank staff speak reasonably fluent English.
Typically, Cypriot banks will lend between 60% and 80% of the value of
the property with the term usually fixed at seven to ten years, although
longer repayment periods can be negotiated. As things stand, it would
be very difficult to obtain a Cyprus mortgage from a non-Cyprus bank.
The Cypriot property lending market did not see the excesses that took
place in the UK and it has not been necessary for the government to support
the banks - yet! Until recently, the Cypriot banking sector was said to
be stable, but exposure to the Greek debt crisis, coupled with the overhang
of bad property lending has caused major jitters in the Cypriot economy,
and in late 2011, the government began to take measures to shore up the
banking system through the creation of a financial stability fund. The
European Union and the International Monetary Fund have become increasingly
concerned at the state of the banking sector in Cyprus, and in early 2012
it remains to be seen if the country can withstand the debt crisis without
international assistance.
In 2012, about EUR200,000 would buy you a detached three bedroom dwelling,
although expect to pay more to get near the beach.
Sample prices from estate agent web sites for the south (2012):
Two-bedroom apartment, 80 sq m, with balcony and communal swimming pool,
EUR80,000; 2 bedroom, 2 storey maisonette in small complex including
swimming pool, EUR130,000;
3-bedroom house with swimming pool, EUR160,000;
Family (4 bedroom) house, big garden, etc EUR250,000;
Recently built (or off plan) high specification villa EUR400,000.
Investing in the North. With the process of rapprochement between the
two communities underway, many brave (mainly British), souls have chanced
their arm with an investment in the northern property market. Whilst there
are unquestionably many property bargains to be had in the beautiful and
still relatively unspoilt north, a note of caution: the risk of losing
your entire investment is a very real threat unless you have a cast iron
guarantee to the title. This is because the Turkish Republic of Northern
Cyprus is legally recognised by very few countries except Turkey, and
therefore the legal position of title deeds issued in the TRNC over the
last few decades is precarious to say the least. A lot will depend on
Turkey's entry into the European Union, if and when it happens. Since
border restrictions were lifted and Greek Cypriots have been allowed to
cross the demarcation line, many have visited land or homes lost after
the Turkish invasion, and may be expected to press for restitution or
compensation in any negotiated bi-communal settlement.
In a famous case, the European Court of Justice ruled in 2009 that a
British woman who had built a house on Greek Cypriot land in the north
must demolish it, and gave permission to the Greek Cypriot courts to enforce
their judgements against UK and EU property owned by the person in question.
The European Court of Human Rights ruled in April 2005 that a claim by
a Greek Cypriot to property situated in the Turkish Republic of Northern
Cyprus was admissible without further recourse to the legal procedures
of the Northern administration. In a unanimous verdict, the seven member
panel at the Strasbourg-based institution, which included a Turkish member,
rejected the notion that a ‘property compensation commission’
established in Northern Cyprus during 2003 to hear claims by dispossessed
Greek Cypriots represented an “effective” or “adequate”
means for redressing the applicant’s complaints. However, the Court
reversed its position in 2010 after the Northern Cyprus 'Commission' settled
a number of cases on apparently favourable terms, and will not now accept
further applications.
Therefore, buying in the north is probably only for the more determined
or adventurous bargain hunter.
Not everybody investing in Cypriot property is doing so with the intention
of living there, and many investors (mainly British) will rent out homes
whilst staying put in their home jurisdiction. Rentals in Cyprus will
generally yield around 8% gross. After various management fees and costs
have taken a bite, yields are 5% at best, but can be slightly less than
3%. And as of early 2012, the lettings market is still in the doldrums,
just like the primary sales market - the number of properties sold in
Cyprus during 2011 fell to the lowest level since records began, according
to figures published in January 2012 by the Department of Land and Surveys.
These figures show that the number of sale contracts deposited in 2011
fell to 7,018, a drop of 18% on the 8,598 deposited during 2010. Sales
to overseas buyers accounted for just under a quarter of all properties
sold.
Real Estate Taxes
Real estate transfer tax is payable on the transfer of a freehold into
the name of the buyer and is levied on a progressive scale between 3%
and 8%.
There is an annual real estate tax based on the 'cadastral' value of
property, which is usually far less than the current market value (it
can be divided between multiple owners). As of January 1, 2012, the rates
are:
0.4% on property ranging in value between EUR120,001 and EUR170,000;
0.5% on property ranging in value between EUR170,001 and EUR300,000;
0.6% on property ranging in value between EUR300,001 and EUR500,000;
0.7% on property ranging in value between EUR500,001 and EUR800,000; and,
0.8% on property ranging in value above EUR800,000.
Prior to January 1, 2012, these rates and thresholds were:
up to EUR170,860 - 0%;
from EUR170,861 to EUR427,150 - 0.25%;
from EUR427,151 to EUR854,301 - 0.35%;
over EUR854,300 - 0.4%.
The immovable property tax is paid on 30th September every year.
A buyer is liable for stamp duty. This is currently charged at a rate
of 0.15% on the first EUR170,000, and 0.2% above this threshold.
Depending on the size of the property, local authority taxes range from
0.1% to 0.5% per annum to cover refuse collection, sewerage, street lighting
etc.
If, as a Cyprus taxpayer or resident, you decide to rent out your Cyprus
property when you are not staying in it, be prepared to pay tax on the
income of between 20-25% if you purchased it through some form of company,
or between 20-45% as an individual. Individual non-resident homeowners
cannot claim all of the deductions that are available to companies, but
can deduct a notional 20% on the rental income independent of whether
any expenses are incurred in deriving the rental income.
Few countries tax their citizens purely on a territorial basis (that
is, only on income obtained from within the country of residence), and
rental income from a property let in Cyprus will almost certainly attract
income tax in your home state should you choose to remain there, not to
mention capital gains tax when the property is sold on.
Income Taxation In Cyprus
Non-residents of Cyprus are taxed in Cyprus on employment income (including
benefits), in relation to services rendered in Cyprus, profits from a
business activity which is carried out through a permanent establishment
in Cyprus, rentals from immoveable property situated in Cyprus, and pensions
in respect of employment exercised in Cyprus, with the exception of pension
paid from a fund established by the Government or local authority.
Chargeable income (after all allowances) is taxed (2012) as follows:
– up to EUR19,500 nil
– from EUR19,501-28,000 20%
– from EUR28,001-36,300 25%
– above EUR36,300 30%
As part of a package of austerity measures approved by parliament in
August 2011, an additional tax band of 35% was imposed on income above
EUR60,000, and applies from the 2011 tax year.
Foreign employees who take up residence in Cyprus and earn in excess
of EUR100,000 per year will be able to claim an exemption from income
tax of 50% of their employment income for a five-year period, starting
January 1, 2012.
Pension income is charged at 5% on amounts over EUR3,417 pa provided
that the individual is neither Cypriot, nor has economic activity on the
island.
A 'Special Defence Contribution' tax applies to foreign-source interest
and dividends received by a resident individual, From January 1, 2012,
these rates are 15% and 20% respectively. The SDC was recently increased
as part of the package of austerity measures approved in 2011, and prior
to January 1, 2012, the rates on interest and dividends were 10% and 15%,
respectively. The SDC on dividends was initially raised to 17% before
being further increased to 20% by parliament in December 2011.
Capital gains tax is charged at the rate of 20% on gains arising from
the disposal of immovable property in Cyprus or the disposal of shares
of companies which own immovable property in Cyprus. Gains from the sale
of shares listed on the stock exchange are excluded from capital gains
tax. The base date for calculating the acquisition cost of real property
is 1st January, 1980 or any later date of acquisition.
The taxable gain is the difference between the proceeds of sale and the
original cost of the property plus the cost of improvements cost, adjusted
for inflation from the date of acquisition.
Some disposals are exempt from taxation, including transfer by reason
of death and gifts between relatives. There are some circumstances in
which rollover relief is available if a gain is used for the purchase
of a further property.
The first EUR85,430 (at the time of writing) of a gain made by an individual
on disposal of a personal property is exempt from tax. This exemption
is available only once.
Capital gains tax does not apply to profits from the sale of overseas
real estate by non-residents, by offshore entities, or by residents who
were not resident when they purchased the asset.
A gain on the disposal of property held by a non-resident (and acquired
with the importation of foreign currency between August 1980-July 1990)
is not subject to CGT.
Cyprus As A Location For Your Assets
So is Cyprus an appropriate location for your assets? If you are a globetrotting
career expat or have a substantial liquid net worth which you would like
to protect from harm, the answer may well be yes. Cyprus is well known
for its financial sector, and the particular expertise on the island is
in the formation and management of offshore holding, investment, and trading
companies, both for expats and corporations. There are a number of reasons
why the country is especially suitable for the groups previously mentioned,
and here we take a look at just a few of them:
Favourable Location. Cyprus is often referred to as a 'European country
in the Middle East', and many people are under the illusion that the island
is actually European. In fact it is located in the north-eastern corner
of the Mediterranean, and is effectively at the crossroads of Europe,
Africa and Asia. This strategic position has played a large part in its
development into a base for expatriates, retirees, and also international
business.
Double Tax Treaties. Unusually for an offshore jurisdiction, Cyprus has
a great many double tax treaties, which can make life a great deal easier
for both resident and non-resident expats with financial concerns and
responsibilities outside the country. There over 40 treaties in all in
place, with several more in the pipeline. Most follow the OECD model,
although the US-Cyprus treaty follows the most recent US agreements. Cyprus
has double taxation agreements in place with countries including:
Armenia, Austria, Belarus, Belgium, Bulgaria, Canada, China, CIS (Former
USSR), Czech Republic, Denmark, Egypt, Germany, France, Greece, Hungary,
India, Ireland, Italy, Kuwait, Kyrgyzstan, Lebanon, Malta, Mauritius,
Moldova, Montenegno, Norway, Poland, Qatar, Romania, Russia, San Marino,
Serbia, Seychelles, Singapore, Slovakia, Slovenia, South Africa, Sweden,
Syria, Tajikistan, Thailand, Ukraine, United Kingdom, United States, Uzbekistan.
Tax Sparing Provisions. In addition to the vast (by offshore jurisdiction
standards, anyway) network of double tax treaties, Cyprus also has a number
of tax sparing provisions in place, whereby if the tax is spared in Cyprus,
it can still be credited against the expat's tax liability in his home
country. These additional arrangements are in place between Cyprus and:
Canada, Czech Republic, Denmark, Germany, Greece, India, Ireland, Italy,
Malta, Romania, Slovakia, Sweden, Syria, United Kingdom, Former Yugoslavia.
Efficient Regulation. The financial sector is regulated by the Central
Bank, and neither individuals nor corporate entities are subject to exchange
controls.
Good Infrastructure. Cyprus has a good, European standard infrastructure,
and in the business world, English is widely spoken. However, a word of
warning - for offshore jurisdictions, Cyprus is a relatively, although
not prohibitively expensive location, and some documents need to be filed
in Greek.
Developed E-Commerce System. The Cypriot government says that the island
is the communications hub for the Middle Eastern region (although don't
they all?). However, the e-commerce situation in Cyprus can certainly
stand up against that of most other offshore jurisdictions, and the Cyprus
Telecommunications Authority boasts a virtually all-digital network. Should
you decide to locate your assets in Cyprus, you should experience no problems
in communicating with your bank or asset manager electronically.
Established Stock Exchange. The Cyprus Stock Exchange (CSE) began operations
in 1996, and is governed by the Stock Exchange Council. The market has
had a few problems in the past, but things seem to be on the up now. In
2007, the CSE and the Athens Stock Exchange launched a new, common trading
platform. Market capitalisation is approximately EUR20bn. The Cyprus Stock
Exchange launched a fully automated online settlement and clearing system
in 2002. On June 24, 2009, the CSE was designated as a recognised stock
exchange by HM Revenue and Customs, the UK tax authority. The CSE is also
regarded as a recognized stock exchange for Inheritance Tax purposes from
the same date.
Types Of Asset Protection Vehicles Available. As previously mentioned,
Cyprus is famed for its expertise in the formation of companies for holding,
investment and trading purposes. As a result, there are a great many variations
on the theme. However, probably the most suitable vehicles for a non-resident
expatriate would be the International Business Company and the International
Trust.
There is nowadays no distinction in taxation terms between an International
Business Company and a regular Cyprus limited company; both pay 10% profits
tax, the lowest rate in the EU.
In July, 2002, as part of the Income Tax Act No. 118(I) of 2002, Parliament
approved the uniform 10% corporate tax rate, to apply to both onshore
and offshore companies, plus a 2% levy on wage bills (meant to subsidise
pensioners), and a 'Special Contribution' related to defence which in
effect applied the 10% corporate tax rate to inter-company dividend and
interest payments. However, under amendments to the tax laws approved
by parliament on August 26, 2011, the SDC on income received by a Cypriot
resident was increased to 17%, and raised again, to 20%, by the Law Amending
the Special Contribution for the Defence Law on December 14, 2011 for
tax years 2012 and 2013. The SDC on interest payments was increased to
15% as of January 1, 2012.
However, profits from activities of a permanent establishment situated
outside Cyprus are completely exempt. This exemption will not apply to
a Cyprus company if: (i) its foreign permanent establishment directly
or indirectly engages in more than fifty per cent (50%) of its activities
in producing investment income, and (ii) the foreign tax burden is substantially
lower than that in Cyprus.
In order to form a company for the purposes of property investment, asset
protection, or estate planning, you will need a bank reference (from an
entity which is recognized by the Central Bank), and a notarised copy
of your passport. Fees and costs vary from provider to provider.
Cyprus International Trust: Trust law in Cyprus is based on English common
law, and the international trust is the most common and advantageous model
for the foreign settlor, as broadly speaking the assets and income of
International Trusts are not taxable in Cyprus (although they may well
be in your home country or country of residence, so seek professional
advice before establishing this type of vehicle for tax minimization purposes).
In order to establish an international trust in Cyprus, the settlor and
beneficiaries must be non-resident, and one of the trustees must be a
Cypriot individual or entity. Client confidentiality is recognized and
protected in the laws of Cyprus, and unless there is concrete evidence
of criminal activity, foreign judgements are not usually recognized. As
well as the costs of setting up and managing a trust structure (which,
as with company formation and management vary considerably), you should
also expect to pay a stamp duty fee. International trust assets may not,
however, contain immovable property in Cyprus.
For more detailed information about the types of asset protection and
business vehicles available in Cyprus, please visit the Lowtax
Jurisdictions Guide.
There are a number of company forms available in Cyprus, but the most
commonly used for a Cypriot holding company is the private limited liability
company. When 100% foreign-owned, a private company used to be referred
to as an 'offshore company', although the expression International Business
Company subsequently came into favour to describe such entities.
Cypriot companies are formed under the Cyprus Companies Law, Cap. 113,
which is virtually a copy of the English 1948 Companies Act. In order
to form a foreign-owned company in Cyprus, a bank reference and copy of
the owner's passport is required for the registration. The bank reference
must be issued by a bank included on the Central Bank of Cyprus's list
of qualifying banks. A holding company using the private limited company
form will need at least one shareholder and the minimum share capital
is EUR1,000, with share capital of between EUR5,000 and EUR10,000 the
norm. A Cypriot private company must have at least one director which
can be a natural person or a body corporate of any nationality.
Under amendments to the Cyprus Company Law in 2003, every company must
prepare a full set of financial statements in accordance with International
Financial Reporting Standards, and every parent company that has one or
more subsidiaries, other than a company which is itself a wholly owned
subsidiary, should present consolidated financial statements. Under article
120, every company must complete an annual return within a period of 42
days from the date of its Annual General Meeting and must file immediately
with the Registrar of Companies a copy of the annual return, signed by
a director and the company secretary. Under article 121, the annual return
filed with the Registrar of Companies must be accompanied by the full
set of financial statements.
So, as described above, due to the island's combination of tax treaties
and low-tax regime, and its membership of the EU, many international investors
choose Cyprus as a location for financial holding and investment companies
as conduits for investment to and from Eastern Europe, the Near and Far
East, and Africa.
Cyprus As A Location For Career Expats And Retirees
Cyprus is a perennially popular location for international consultants,
and independent contractors, and its burgeoning offshore sector accounts
for the greatest percentage of expatriate workers, for reasons which we
will examine later. However, it is also a popular destination for active
retirees, (who are attracted not just by the lifestyle on offer, but by
the fact that the large number of double taxation treaties in place mean
that retirement income from abroad will not usually be subject to withholding
tax at source) and both of these groups are positively encouraged by the
Cypriot government. In this section of the focus on Cyprus, we will be
looking at the requirements for entry and residence, working, living,
and buying property on the island, and the taxation liabilities for both
resident and non-resident expatriates.
Since Cyprus joined the EU, residency and work permits are no longer
required of EU citizens. However, for non-EU citizens, employees of entities
in Cyprus require 'Temporary Work and Residence (TRE) Permits', which
are issued by the Civil Registry and Migration Department (CRMD). For
this purpose, employees are categorized as Executives Directors, Other
Executives and Middle Management Staff, and Support Staff. In effect,
Executives Directors are defined as senior management, and only five are
permitted per company unless the Ministry of Labour can be persuaded otherwise.
The minimum salary for an Executive Director is CYP24,000 per year and
for Middle Management Staff the minimum salary is EUR12,000 per year.
In all cases, a fair amount of documentation is required by the authorities
and permits are normally issued for 2 years, renewable for a further three
years.
Non-Executive TREs are harder to obtain, as it must be proven that there
is no suitably qualified Cypriot that could fill the position, and must
be applied for through the Ministry of Labour. Non-executive applicants
are advised not to commit themselves to a position in Cyprus before consulting
the Ministry of Labour.
However, temporary residence and employment permits are issued fairly
freely to employees of, or consultants, to offshore operations, and also
to foreign nationals wishing to retire to the island, hence their preponderance
there. The first TRE permit is granted by the Migration Department of
the Ministry of the Interior, and is usually valid for a two-year period,
renewable every three years after that. However permits issued to intending
retirees are only valid for a one-year period, and are renewable annually
thereafter, subject to a demonstration of adequate financial resources.
Before November 2000, an expatriate had to have obtained a (rare) five-year
permit, or to have been resident in the country for five years, before
they were permitted to bring their spouse and/or children to live with
them. However, new legislation introduced at the end of 2001 means that
for workers in the education, foreign media, offshore, and accounting
sectors, and for those that have invested significant sums in local enterprise,
this rule has been significantly relaxed.
Shipping Registration In Cyprus
This may seem like an unlikely topic to include in a jurisdictional focus,
but sailing is fast becoming a very popular pastime with active expatriate
retirees and HNWI, and if this pastime interests you, then Cyprus is the
place to be. Of recent years, Cyprus has developed a maritime policy which
is highly favourable for ship owners (in Cyprus there is no distinction
made between ships and pleasure craft such as yachts, other than the fact
that the procedures for the registration of the latter are more simple
and straightforward), and there is a fast efficient infrastructure in
place to deal with the burgeoning demand. A number of tax incentives combine
with this to make Cyprus one of the most attractive locations for ship
registration.
The first step for a non-Cypriot ship owner wanting to register a vessel
under the Cyprus flag is to form a shipping company which will acquire
the vessel in its name. Broadly speaking there are two different types
of ship-owning company, but of these, only the first will probably be
of interest to nautically minded expatriates, as the second restrict themselves
to activities such as ship management, broking, average adjusting and
marine insurance, and are subject to income tax.
Yachts and other pleasure craft may be registered in Cyprus provided
that they are used exclusively for recreation and are not engaged in any
commercial operations, irrespective of size. Vessels in this category
which do not exceed 25 years of age may be registered without any additional
conditions. Vessels exceeding 25 years of age must pass an entry inspection.
The most suitable models for expatriates restrict their activities to
the ownership, bareboat (self-sail) chartering and operation of ships
in international waters, and are totally exempt from income tax, capital
gains tax, and stamp duty on documents or mortgage deeds. Numerous marinas
have been constructed in Cyprus, and more are on the way, many with very
high specification infrastructure.
Conclusion
So in the final analysis, is Cyprus a good location for your assets,
yourself, your family, your boat, or (e) all of the above? Depends what
you are looking for. Cyprus is not one of the cheapest offshore jurisdictions
available, but nor is it one of the most expensive in which to locate
an offshore structure, or spend your retirement. There is an efficient
and well-maintained infrastructure in place, and the standard of living
is high for the most part.
The government usually encourages independent contractors, offshore employees,
and those who wish to retire to Cyprus, and although residents are subject
to income tax, for the most part this is only levied on income deemed
to have arisen in Cyprus. Although it has shied away from the 'offshore'
image it once had, and has been forced to implement some changes to its
legislation in order to satisfy the OECD, it is still generally regarded
as a safe and secure location in which to do business or reside, and as
a shipping registration location, it is widely considered to be unparalleled.
For up-to-date news about the offshore and taxation regime, visit the
Cyprus section of Tax-news.com
and see the Tax-News
Cyprus Review.
For general Information on Cyprus, visit WindowOnCyprus.com
Other Useful Links
Cyprus Yellow Pages
Lonely Planet- Destination
Cyprus
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