Designing and implementing international corporate structures that balance tax efficiency, commercial flexibility, regulatory compliance, and long-term durability.
Corporate structuring is not simply about minimising tax. It is about creating a framework that supports the business's commercial objectives, satisfies the regulatory requirements of every relevant jurisdiction, and remains defensible under scrutiny. Cyprus is one of Europe's most effective jurisdictions for international corporate structures — offering holding company advantages, financing structures, SPV frameworks, and IP holding arrangements that genuinely work at the commercial, legal, and tax levels simultaneously. We advise on the design and implementation of structures from the ground up, as well as the restructuring and rationalisation of existing group arrangements. Our work typically involves close coordination with advisers in other jurisdictions, and we have established working relationships with trusted counsel across Europe, the Middle East, and Asia.
Cyprus holding companies benefit from full dividend exemption, zero withholding on outbound distributions, and no capital gains tax on share disposals
Financing structures through Cyprus can provide interest deductions at the subsidiary level while the interest income is taxed at 15% in Cyprus — or lower with treaty planning
Cyprus SPVs are widely used in private equity, real estate, and debt capital markets transactions across Europe and the Middle East
Common-law-influenced legal framework provides commercially familiar documentation for sophisticated institutional investors
Full EU regulatory framework provides certainty and enforceability across member states
Court proceedings are conducted in Greek, with established EU mechanisms governing recognition and enforcement of judgments
Efficient and cost-effective corporate administration compared to most Western European jurisdictions
Scalable structures that can accommodate future investment rounds, shareholder changes, and expansion
Every structure begins with an objectives conversation. We need to understand what the client is trying to achieve — not just the legal outcome, but the commercial reality behind it. Is this a structure for a family business that wants to protect assets across generations? A technology company preparing for a Series B round with US investors? A private equity fund seeking to dispose of a portfolio company in a tax-efficient manner? Once we understand the objectives, we identify the appropriate structure and model its tax consequences across all relevant jurisdictions. Where the structure involves other jurisdictions, we coordinate with local counsel to confirm that the Cyprus elements integrate correctly with the local requirements. We then implement the structure — drafting and executing all necessary documents, registering the relevant companies, and establishing the governance framework. After implementation, we support ongoing compliance: board meetings, corporate secretarial filings, annual returns, and the substance requirements that underpin the structure's defensibility.
Every structure is different. An initial conversation helps us understand your objectives and identify the most effective path forward.
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