Tax & Regulatory Updates | ATB Advisors Ltd
ATB Advisors Logo

ATB Advisors Ltd

Assurance Redefined
www.atb.com.cy  |  info@atb.com.cy
+357 24817333 • 81 Griva Digeni Avenue, Larnaca

Cyprus Tax & Regulatory Updates

Key legislative changes affecting individuals, companies, and investors — curated by ATB Advisors Ltd.

02
Apr 2026

FDI Cyprus Introduces FDI Screening Regime — Key Implications for Transactions New

Cyprus has enacted the Establishment of a Framework for the Screening of Foreign Direct Investments Law of 2025 (Law 194(I)/2025), creating a national FDI screening regime effective 2 April 2026. Certain foreign investments into strategically sensitive sectors now require prior approval.

▾ Click to read full article
Overview

Cyprus has enacted the Establishment of a Framework for the Screening of Foreign Direct Investments Law of 2025 (Law 194(I)/2025), designating the Ministry of Finance as the competent authority. The law entered into force on 2 April 2026. The new regime introduces a prior approval requirement for certain foreign investments into Cypriot businesses operating in strategically sensitive sectors, meaning some transactions will require FDI analysis at the front end of deal planning.

When Does Mandatory Notification Arise?

A mandatory notification may arise where the investor qualifies as a foreign investor and the following three conditions are met cumulatively: the transaction results in the acquisition of a “special participation” (at least 25% of the share capital and/or voting rights or equivalent decisive influence), the investment value reaches €2 million or more, and the target is an undertaking of strategic importance.

Strategic Importance — Broad Scope

The concept of strategic importance goes beyond traditional defence or utilities cases. It extends to sectors such as energy, transport, water, health, education, tourism, communications, media, data processing and storage, financial services, and critical technologies including artificial intelligence, semiconductors, cybersecurity, biotechnology and other dual-use or sensitive technologies.

Review Process & Timelines

The review process has two main stages. First, the competent authority decides within 20 working days whether the notified investment will be subjected to review. If the matter proceeds to full review, the authority must decide within 65 working days whether the transaction may affect the security or public order of Cyprus. Both time periods may be suspended if further information is requested, and clearance is effective only once written approval is issued.

Authority Powers & Call-in Mechanism

The authority may approve a transaction subject to conditions, prohibit it, terminate it or reverse it. If an investor fails to comply with imposed conditions, the authority may restrict the exercise of rights arising from the investment, including voting, management and control rights. Even where a transaction does not fall within the mandatory filing criteria, the authority may still review it within 15 months of completion. Where a mandatory filing should have been made but was not, the authority may intervene for up to five years after completion.

Penalties

Administrative penalties are material. The law provides for fines for failure to notify, for false or misleading information, for failure to provide information and for non-compliance with measures imposed by the authority, including daily penalties for continuing breaches.

Practical Implications

Cyprus FDI risk now needs to be built into transaction screening, diligence, structuring, SPA conditions precedent, long-stop dates, information requests and regulatory risk allocation. Businesses with live or pipeline transactions should take immediate action. Contact ATB Advisors Ltd for a detailed assessment of how this regime may affect your current or planned transactions.

19
Mar 2026

Income Tax “Brain Gain” Initiative — New Income Tax Incentive for Returning Professionals

As part of the “Brain Gain” initiative, Cyprus has introduced a new income tax incentive aimed at attracting highly skilled professionals and Cypriot expatriates to relocate (back) to Cyprus.

▾ Click to read full article
Overview

As part of the “Brain Gain” initiative, Cyprus has introduced a new income tax incentive aimed at attracting highly skilled professionals and Cypriot expatriates to relocate (back) to Cyprus. The incentive offers a significant exemption on employment income for qualifying individuals who take up employment in Cyprus, strengthening the island’s position as a talent hub.

Income Tax Exemption

Qualifying individuals who relocate to Cyprus for employment benefit from a significant exemption on employment income. The exemption applies for a defined period following the commencement of employment in Cyprus.

Who Qualifies

The incentive targets individuals who were previously non-residents of Cyprus and who take up first-time employment or return to employment in Cyprus after an extended period abroad. Specific eligibility criteria apply.

Practical Implications

Particularly relevant for employers seeking to attract international talent and for Cypriot professionals considering a return home. Contact ATB Advisors Ltd for a detailed assessment of eligibility and tax planning opportunities.

27
Mar 2026

Reporting DAC8 Directive — Cyprus Law Enters into Force New

On 27 March 2026, Cyprus transposed EU Directive 2023/2226 (DAC8) into domestic law. The new rules impose mandatory reporting obligations on Crypto-Asset Service Providers (CASPs) and extend the scope of existing CRS obligations, with information automatically exchanged with EU tax authorities.

▾ Click to read full article
Overview

On 27 March 2026, the law amending the Law on Administrative Cooperation in the field of Taxation (Law N. 205(I)/2012) was published in the Official Gazette of the Republic of Cyprus and entered into force. The Law transposes EU Directive 2023/2226 of 17 October 2023 (DAC8) into domestic law and is broadly aligned with the provisions of the Directive.

Crypto-Asset Reporting

The Law introduces mandatory due diligence and reporting obligations on Crypto-Asset Service Providers (CASPs) and Crypto-Asset Operators. This establishes a framework for automatic exchange of crypto-asset information with EU tax authorities.

Extension of CRS Obligations

The existing obligations of Financial Institutions under the Common Reporting Standard (CRS) are extended in scope, broadening the categories of financial information subject to automatic exchange.

Cross-Border Rulings for HNWIs

A new framework is introduced for the automatic exchange of certain advance cross-border rulings granted to high-net-worth individuals, increasing transparency for complex international tax arrangements.

Practical Implications

CASPs, financial institutions and businesses with crypto-asset exposure should review their reporting obligations under the new framework. Contact ATB Advisors Ltd for a detailed assessment of how DAC8 affects your compliance position.

Need Guidance on the New Legislation?

Our team is here to help you understand how these changes affect your business or personal tax position.

§

Income Tax

Corporate Income Tax (CIT)

The standard corporate tax rate rises from 12.5% to 15%. The effective tax rate under the IP Box rises from 2.5% to 3%.

Income Tax Bands (Individuals)

The individual tax-free threshold increases from €19,500 to €22,000. Revised bands:

Taxable IncomeRate
Up to €22,0000%
€22,001 – €32,00020%
€32,001 – €42,00025%
€42,001 – €72,00030%
Over €72,00035%
Tax Loss Carryforward

The period for carrying forward tax losses is extended from 5 to 7 years.

Share Option Plans

New provisions introduce a flat 8% tax rate on share option schemes, subject to specific conditions.

Tax Residency — Individuals

The requirement for a person to not be tax resident in another jurisdiction is removed from the 60-day tax residency rule.

Tax Residency — Companies

Corporate tax residency is now determined by place of incorporation, without the condition of non-residency in another state, unless overridden by a Double Tax Treaty.

Ex-Gratia Payments

Lump sums exceeding €200,000 for retirement, job termination, or appointment are subject to a flat 20% tax rate.

New Personal Deductions

Subject to income level, individuals may now claim deductions for:

  • Dependent children and university students
  • Mortgage interest or rent for main residence
  • Insurance against natural disasters on residence
  • Energy efficiency expenses
  • Purchase of electric vehicles
Entertainment Expenses

The deductible cap for entertainment-related business expenses increases to €30,000 (from €17,086).

Research & Development

A 20% additional deduction is available on qualifying R&D and scientific research costs incurred from 2022–2030.

Amortisation of Intangibles

Intangible assets with indefinite useful lives may be amortised over a maximum of 20 years.

Fund Redemptions

From 1 January 2031, net proceeds from the redemption of units/shares in collective investment schemes by individuals will be treated as dividends.

Insurance Sector

The minimum tax previously applicable to insurance companies is abolished.

Overview

As part of the “Brain Gain” initiative, Cyprus has introduced a new income taxincentive aimed at attracting highly skilled professionals and Cypriot expatriates to relocate (back) to Cyprus. The incentive offers a significant exemption on employment income for qualifying individuals who take up employment in Cyprus, strengthening the island’s position as a talent hub.

Income Tax Exemption

Qualifying individuals who relocate to Cyprus for employment benefit from a significant exemption on employment income. The exemption applies for a defined period following the commencement of employment in Cyprus.

Who Qualifies

The incentive targets individuals who were previously non-residents of Cyprus and who take up first-time employment or return to employment in Cyprus after an extended period abroad. Specific eligibility criteria apply.

Practical Implications

Particularly relevant for employers seeking to attract international talent and for Cypriot professionals considering a return home. Contact ATB Advisors Ltd for a detailed assessment of eligibility and tax planning opportunities.

Overview New

On 27 March 2026, the law amending the Law on Administrative Cooperation in the field of Taxation (Law N. 205(I)/2012) was published in the Official Gazette of the Republic of Cyprus and entered into force. The Law transposes EU Directive 2023/2226 of 17 October 2023 (DAC8) into domestic law and is broadly aligned with the provisions of the Directive.

Crypto-Asset Reporting

The Law introduces mandatory due diligence and reporting obligations on Crypto-Asset Service Providers (CASPs) and Crypto-Asset Operators. This establishes a framework for automatic exchange of crypto-asset information with EU tax authorities.

Extension of CRS Obligations

The existing obligations of Financial Institutions under the Common Reporting Standard (CRS) are extended in scope, broadening the categories of financial information subject to automatic exchange.

Cross-Border Rulings for HNWIs

A new framework is introduced for the automatic exchange of certain advance cross-border rulings granted to high-net-worth individuals, increasing transparency for complex international tax arrangements.

Special Contribution for Defence (SDC) Tax Law

Dividends

The SDC rate on dividends for Cyprus-domiciled individual residents is reduced from 17% to 5%.

Rental Income

SDC on rental income is eliminated. Rental income continues to be subject to income tax.

Deemed Dividend Distribution

These provisions no longer apply to corporate profits earned from 1 January 2026.

Legacy Dividends

Dividends distributed from profits up to 31 December 2025 remain taxed at 17% for Cyprus-domiciled individual residents.

Capital Reductions

Any capital reduction represented by property distributions will be subject to tax on the difference between the market value and the amount originally paid in.

Bonus Shares

Share capital increases through bonus issues will be treated as dividends.

“Concealed” or “Disguised” Dividends New

A new flat 10% tax applies to private use of company assets by shareholders or the undervalue disposal of company assets to shareholders or connected persons.

Non-Dom SDC Exemption Extension

The 17-year exemption may be extended through a €250,000 lump sum for each additional 5-year period (i.e. €50,000/year, for up to 10 more years).

Bonds & Investment Interest Income

The withholding rate of SDC on interest from EU government bonds and Health Insurance Fund deposits is reduced to 3%.

Dividends to Blacklisted Jurisdictions

A 17% withholding tax is imposed on gross dividends paid to companies in blacklisted jurisdictions.

Dividends to Low-Tax Jurisdictions

A 5% withholding tax is imposed on dividends paid to companies in low-tax jurisdictions.

Penalties

Fines and penalties for non-compliance have increased.

Capital Gains Tax (CGT) Law

Definition of Share Ownership

Amended to include shares deriving 20% (previously 50%) of their value from immovable property situated in Cyprus.

Exemptions

Higher exemption limits for disposals of immovable property, agricultural land, and main residences.

Listed Shares

CGT exemption for Nea Agora shares abolished for newly listed firms. Exemption now applies only to shares on a regulated market of a recognised Stock Exchange.

Unlisted Shares

An annual €50,000 exemption applies for gains on non-regulated market shares.

Exchange of Land for Plots/Buildings

These transactions are now exempt from CGT.

Enforcement

Penalties and fines have been substantially increased.

📜

Stamp Duty Law

Full Abolition Abolished

The Stamp Duty Law is abolished entirely. No stamp duty is payable on any documents or transactions going forward.

Crypto Asset Taxation (Article 20E)

Flat Tax Rate New

A flat 8% income tax rate on profits from the disposal of crypto assets, effective 1 January 2026.

Scope

Applies to both individuals and legal persons. Crypto profits are not aggregated with other income.

Definition of Crypto Assets

Aligned with the EU MiCA Regulation. Covers coins, tokens, stablecoins, utility tokens, and many non-security NFTs.

Loss Set-Off

Losses from crypto disposals may only be set off against crypto profits within the same tax year.

Transfer Pricing

Local File Thresholds (2026 onwards)

Revised thresholds for preparing a local file:

>
Transaction CategoryThreshold
Goods€5,000,000
Financing transactions€10,000,000
All other transactions€2,500,000

Simplified documentation for transactions below thresholds remains in effect.

Collection & Assessment of Taxes

Commissioner Powers

Authority to pledge taxpayer-owned shares if outstanding tax exceeds €100,000. May also suspend operations for persistent non-compliance.

Mandatory Filing New

All tax-resident individuals aged 25–71 must file a personal tax return, even with no income. All individuals with income must file regardless of age.

Statute of Limitations

Remains 6 years, but now starts from the date of return submission (not year-end).

Audit Threshold

Raised from €70,000 to €120,000 annual gross income for sole traders.

Director Liability

Directors remain liable for actions during their term, even after resignation.

📅

Compliance & Filing Deadlines

Annual Tax Returns

Due by 31 January, 13 months post tax year-end (previously 15 months). Payment deadline aligned with return submission.

TD7 Submission Date

Set to 31 March following the relevant tax year.

Employer Reporting

Enhanced requirements for submitting employee-related information on Form TD7.

Partnerships

Partnerships must now submit tax returns.

Objection Deadline

Increased to 60 days.

Rent Payments

Must be made via bank transfer or electronic payment. Cash not allowed.

Refund Interest

Now paid four months after the return submission deadline or refund determination.

Increased Penalties

Non-compliance fines have risen significantly across all areas.

Need Guidance on the New Legislation?

Our team is here to help you understand how these changes affect your business or personal tax position.

📅

Indicative Tax Calendar for Tax Year X

The table uses X for the tax year, X-1 / X-2 for prior years. Replace with the relevant year.

Obligation31/131/331/731/12
Payment of SDC for deemed dividend distribution purposes of [Year X-2] (only for years 2024 & 2025)
Corporate tax return & payment of final tax of [Year X-2] — non-Cyprus tax resident companies with Cyprus-taxable income 1
Corporate tax return & payment of final tax of [Year X-2] — Cyprus tax resident company
Personal tax return & payment of final tax of [Year X-1] — individuals not preparing accounts 2
Personal tax return & payment of final tax of [Year X-1] — individuals preparing accounts 2
Personal tax return & payment of final tax of [Year X-1] — non-Cyprus tax residents with Cyprus-taxable income
Submission by employers of total payroll of [Year X-1] (Form TD7) 3
Payment of first / second instalment of provisional tax for [Year X] 4
Last day for submission of revised temporary tax
Payment of SDC for [Year X] on dividends & interest from sources outside the Republic Paid by self-assessment by the deadline for the relevant tax return
Payment of SDC withheld on dividend & interest 5 End of following month
Payment of PAYE (tax withheld from employee’s salary) End of following month
Payment of tax withheld on payments to non-Cypriot tax residents End of following month

Notes:

1 A non-resident company whose entire gross income taxed under the ITL has been subject to WHT is exempted from filing a tax return.

2 All individuals between 25 and 71 (inclusive) must submit a personal tax return. Others only need to file if they have taxable income.

3 The TD7 shall include all full-time and part-time employees, employees under contract, pension recipients, and persons to whom a facility or benefit was provided.

4 For companies incorporated/becoming Cyprus tax residents, and individuals that began earning non-emolument income in [Year X], provisional tax shall be submitted and paid by 31 December of [Year X].

5 SDC on dividends from 2024 and 2025 profits shall be paid on 31 December 2028 and 31 December 2029, respectively.

Transitional rule: For pre-2025 tax years, where the filing date was 31 July, the payment deadline remains 31 July following the tax year. Where the filing date was 31 March, the payment deadline becomes 1 August following the tax year.

Need Help With Your Filing Deadlines?

Let us ensure you never miss a deadline. Our team manages compliance calendars for businesses of all sizes.

Disclaimer: This page is prepared for general informational purposes only and does not constitute professional tax, legal, or financial advice. The information is based on applicable Cyprus legislation and subsequent amendments as published in the Official Gazette. For professional assistance or guidance, please contact ATB Advisors Ltd.
ATB Advisors Ltd • 81 Griva Digeni Avenue, Marinos Court, 2nd Floor, 6043 Larnaca, Cyprus
P.O. Box 42656, P.C. 6501 • info@atb.com.cywww.atb.com.cy
© 2026 ATB Advisors Ltd. All rights reserved.
Assurance Redefined