Substance in Cyprus

From 2026 a company incorporated in Cyprus is tax resident here by default unless a tax treaty says otherwise; a foreign company is resident when it is managed and controlled in Cyprus, so where its directors meet and decide matters. Banks and foreign tax authorities look at the same facts. We plan what your company needs.

Key testIncorporation; management and control
IncludesDirectors, office, staff
Matters forTax and banks
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Limassol seafront towers and marina on a sunny morningChecked 29 October 2026

Steps and timeline

  1. 1

    Review

    How decisions are made today.

    1–2 weeks
  2. 2

    Plan

    Directors, board meetings, office.

    2–4 weeks
  3. 3

    Maintain

    Minutes, records, presence.

    ongoing

Documents

Evidence of management in Cyprus

0 of 6 ready

Official form: T.D.98 (Τ.Φ.98) · how to fill it in

The exact list depends on your situation; we confirm it before filing.

Who does what

What you do

  • Share your situation and goals
  • Collect documents from home
  • Agree the scope of work in writing

What we do

  • Check the requirements for your case
  • Prepare the documents and file the application
  • Follow up until the decision

Your coordinator

  • Plans the work and next steps
  • Keeps one timeline for everything
  • Reminds you of renewals and deadlines

Common mistakes

  • Directors abroad who take decisions by email, with Cyprus minutes written afterwards
  • A general power of attorney for someone living abroad
  • Signing key contracts outside Cyprus
  • Cyprus directors who only sign what is sent to them
  • Holding the board meeting by video with most directors abroad

What affects the cost

The price depends on your situation. We explain the scope and expected costs before work begins.

Number of directors and where they liveBoard meetings a yearOffice and staffGroup structure and treaties

Questions

Is a nominee director enough?

Usually not; decisions must really be made in Cyprus.

What does real management in Cyprus look like?

Most directors live in Cyprus. Board meetings take place here, and the directors who attend decide the key matters: contracts, budgets and the accounts. Minutes, books and records are kept in Cyprus. The Tax Department's questionnaire for a company's residence certificate asks about the same facts.

What happens if my home country says the company is managed there?

Example: your Cyprus company makes €300,000 of profit and pays 15%, €45,000, in Cyprus. If you make the decisions from Germany, Germany can treat the company as resident there. It then taxes the same profit at its own rates. Getting the double tax removed then takes a treaty procedure between the two tax offices, which can last years.

Does a holding company need an office and staff?

Less than a trading company. A holding company still needs directors who decide in Cyprus and records kept here. A trading company that serves clients is also judged on its office, staff and where contracts are signed. Banks ask the same questions when they open and review your account.

Can board meetings be held by video?

Only with care. What counts is where the directors are when they decide. A call with most directors abroad points to management abroad. We plan the meetings in Cyprus and keep travel records that show who attended from here.

Sources

Figures checked 29 October 2026. Rules change: we confirm them for your case before you act.

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A coordinator replies within one working day with the next steps.

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