Introduction Of Additional Corporate Tax Residency Test

In summary

On 21 December 2021, an amendment to the Income Tax Law was published in the Cyprus Government Gazette ("Law amendment") whereby an additional corporate tax residency test is introduced based on incorporation. This additional test aims to capture Cyprus incorporated / registered companies that are not tax resident in any other jurisdiction (commonly referred to as "stateless companies").

The Law amendment will enter into force on 31 December 2022.

Existing corporate tax residency rules based on management and control

In accordance with the Income Tax Law, a company is considered to be a tax resident of Cyprus if its management and control is exercised in Cyprus.