As a result of heavily publicised negotiations in August, a protocol amending the long standing double taxation treaty has been signed between Russia and Cyprus (each, a “Contracting State”) on the 8th of September 2020.

The crucial features of the amending protocol are the following: -

  1. Dividends:

Regarding the tax withheld from the Contracting State of which the company paying the dividends is a resident, the protocol sets a limit of 15%, where the beneficial owner of the dividends is a resident of the other Contracting State.

However, the parties have agreed exceptions to the above whereby a 5% withholding tax will apply where the recipient/ benef...

September 14, 2020

A Protocol updating the Double tax treaty between Cyprus and Switzerland has been signed on 20th of July 2020, in an effort to further develop the economic relationship of the two States as well as to enhance their cooperation on tax matters. The agreement, as with the bulk of Cyprus’ double tax treaties  is based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital.

The main amendments as published in the Official Gazette on 24 of July 2020, are the following:

1. Business profits:

A Contracting State shall make no adjustment to the profits that are attributable to a permanent establishment of an enterprise of one of...

September 4, 2020

The initial implementation of the Cyprus Investment Programme (the “CIP”) took place by the Cyprus Government in 2013 aiming to alleviate the economic consequences that followed the financial crisis at the time. However, due to the recent criticism that the CIP has received at a European level, the Cyprus Government, through the approval of the Council of Ministers, has introduced various strict amendments and conditions in order to improve and upgrade the Programme.

Some of the most significant amendments of the CIP as published in the Official Cyprus Gazette on Tuesday 18th August 2020, are the following:-

1.      Honorary naturalization...

May 6, 2020

Yacht Leasing Scheme Cyprus

Cyprus enjoys a favorable tax system in line with the EU requirements and OECD principles. In order to qualify under the Cyprus Yacht Scheme the applicant must incorporate a Cyprus company and lease out the yacht through that company provided that the applicant satisfies the following requirements, instead of buying the yacht outright and paying the full VAT on the transaction, noting that the current VAT rate in Cyprus is 19%.

Requirements – Cyprus Yacht Scheme

  1. A lease agreement must be concluded between a Cyprus company and an individual or legal person, whereby the lessee is granted the option to purchase the yacht at a...

April 2, 2020

Re-domiciliation of Foreign Companies to Cyprus

Foreign companies which are incorporated and they are currently operating in a different jurisdiction can transfer their seat to Cyprus and at the same time companies established in Cyprus can relocate their seat abroad as per the provisions of the Companies Law, CAP 113. Following the re-domiciliation, foreign companies that redomicile their seat to Cyprus can continue to exist and operate under the laws of Cyprus and cease to exist under the jurisdiction of incorporation.

Foreign companies can redomicile for various reasons including among other to take advantage of the Cyprus favorable tax regime. Foreig...

March 20, 2020

Measures undertaken by the Registrar of Companies to assist Cyprus companies affected by COVID 19

Following the measures taken by the Cyprus government to support companies and businesses affected by the strict measures imposed to limit the spread of COVID-19, the Registrar of Companies announces the following measures:

1. The submission of due Annual Reports:

The publication process at the Official Gazette of the Republic of Cyprus following the three months' notice before the strike off of non-compliant companies is now suspended until January 2021.

2. Payment of the annual levy:

The deadline to pay the annual levy for 2020 is extended until 31st December...

January 23, 2020


The Cyprus Securities and Exchange Commission (the “CySEC”) has issued a Policy Statement setting out its finalised rules for investment-based crowdfunding which will be implemented by the way of a CySEC Directive due to be published in the official Gazette imminently.

Crowdfunding may constitute an alternative method to traditional financing via which small and medium enterprises (“SMEs”) can obtain access to financing through the issuance of transferrable securities such as shares or debt instruments. Any potential investors can access these investment opportunities through an internet-based elect...

January 8, 2020

Setting up an Electronic Money Institution in Cyprus

Licensing and supervision of Electronic Money Institutions

In Cyprus the provision of electronic payment services is regulated by the Provision and Use of Payment Services and Access to Payment Systems Law 31(I)/2018 of 2018 and the Electronic Money Law of 81(I)/2012 (the "Laws") as amended which transposed the EU Directive 2015/2366. The provision of electronic services in Cyprus can be provided by an Electronic Money Institution (the “EMI”) which has been granted an authorisation by the Central Bank of Cyprus (the “CBC”).

Electronic Payment Services:

1. Services enabling cash to be placed on a payment...

November 25, 2019

Amendments to Cyprus Companies Law, CAP 113

Following recent amendments to the Cyprus Companies Law, Cap. 113 (the “Law”), the Registrar of Companies has now introduced new provisions aiming in further modernising the current legislative framework which shall be effective from 18th December 2019 onward.

A. Late Filing Penalties

1. Annual Return

The Registrar of Companies will now impose an administrative fine for the late submission of the annual returns of each Cyprus of (i) €50; plus (ii) an additional charge of €1 for each day of delay for the first 6 months and thereafter €2 for each day of delay, up to a maximum of €500.

Therefore, all companies which...

MARILOU PAVLOU CHRISTODOULIDES LLC has now been approved as a Nominated Advisor (NOMAD) in listing companies in the Emerging Companies Market of Cyprus Stock Exchange.

We are proud to announce that we are officially authorised to act and assist as a Nominated Adviser (a “NOMAD”) to companies that wish to be listed and traded in the Emerging Companies Market (the “ECM”) of the Cyprus Stock Exchange (the “CSE”). 

The ECM benefits from a simplified regulatory regime specifically designed for small and medium sized companies. It is considered as a Multilateral Trading Facility (MTF) according to Mifid II legislation and offers various advantages to companies...

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