Cyprus

A company is tax resident of Cyprus if it is managed and controlled in Cyprus.

As of 2023, a Cyprus incorporated company is by default considered a tax resident of Cyprus provided it is not tax resident in any other jurisdiction.

As of 2026, a Cyprus incorporated company is by default considered a tax resident of Cyprus, unless a DTT provides otherwise.  

For the purposes of this incorporation tax residency test, companies that have transferred their registered office or legal seat to Cyprus will be considered as being incorporated in Cyprus. 

Permanent establishment (PE)

Cyprus domestic income tax legislation explicitly provides for the determination of a taxable Cyprus PE of a non-Cyprus tax resident company. These specific legislative provisions are broadly in line with the relevant article of the 2014 Organisation for Economic Co-operation and Development (OECD) model DTT, with the addition of offshore activities relating to the exploration, extraction, or exploitation of the seabed, subsoil, and natural resources, as well as the installation and exploitation of pipelines and other installations on the seabed.