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Amendments to the Cyprus tax laws

In July 2015 the Cyprus government submitted a number of draft laws to parliament to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax regime and make it more attractive, fair, and effective, with the aim of stimulating economic activity and attracting inward direct investment.

Certain of the proposals, including the introduction of a non-domiciled regime for Special Contribution for Defence, a notional interest deduction for new equity capital introduced into companies, and a capital gains tax exemption for disposals of immovable property acquired between 16 July 2015 and 31 December 2016, were enacted immediately. Lack of parliamentary time resulted in consideration of the other proposed amendments being deferred until after the parliamentary recess.

On 10 December 2015 the remaining amendments to the tax laws were enacted by parliament and will enter into force on publication in the government gazette, which is likely to occur before the end of 2015.

The changes include:

  • New provisions to simplify taxation of offshore hydrocarbon activities.
  • Alignment with the latest amendments to the EU Parent-Subsidiary Directive.
  • Extension of group relief to overseas companies.
  • Changes to arm’s length adjustments.
  • Tax neutrality of foreign exchange gains and losses.
  • Limitation of losses carried forward on IP activities.
  • Anti-abuse provisions for corporate reorganisations.
  • Extension of income tax exemption for new individual taxpayers.
  • Changes to capital gains tax relating to shares in companies holding real estate in Cyprus.

We will publish a full analysis as soon as the new laws are issued in their final form.