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Cryptocurrency taxation in Cyprus is governed by the general provisions of several existing laws, as there is no specific legislation targeting cryptocurrencies. For instance, the Income Tax Law (118(I)/2002) is key to determining how income from cryptocurrencies is taxed, and in the absence of...

This will be 2.5% as long as there are internal development costs or costs outsourced to non-related parties. If you incur outsourced R&D service from related parties this will limit your deduction. Thus, a simple setup in case you are the sole developer is setup the company and arrange to be an...

To qualify for the IP Box regime the injected (ready to be used) IP needs to be subject to ongoing development (R&D) which is either incurred internally by the company or outsourced to a non related party. The development work must relate to enhancements/improvements or add-ons of the existing...

Hello, VAT should be charged on the total selling price to the consumer. You have eligibility to claim VAT back from VAT imposed through customs in Germany. You will need a German VAT number and fill the VAT forms

In Cyprus you pay tax on what you declare on your personal tax form. A tax assessment letter usually is delivered by the lapse of 6 years time. That is, for 2023 a tax assessment letter for 2017 will be sent and if any balance exists will be paid./refunded with interest and penalties. The only...

Yes, the threshold applies to both EU and non-EU sellers that perform supplies to consumers in the EU. See all info here: VAT for e-commerce

The threshold is 10,000 Euro for intra-European sales. If this is not exceeded and the seller is established in just one Member State, the seller should only have to charge VAT in the Member State where he is established, unless he opts for VAT in the Member State of destination of the...

Yes, you can use OSS/IOSS platform. You need to register to a single Member State for VAT and make B2C declarations in OSS platform to that State. The payment is done to a single Authority (the Central Bank) which distributes VAT payments to each tax office of each Member State. Pm me if you...

Just to clarify there are no 90 days and 60 days certificates in Cyprus. The available certifocates are tax resident certificate, non-domiciliation certificate, and tax registration certificate. All those certificates do not mention whether the 60 days or 183days elections

You are correct on the fact that gains from trading financial instruments is not explicitly mentioned on the circular and also not nentioned in the income tax law. However, this income is captured under income tax law art. 5(a) and then exempted from tax under article 8 (22). In the GHS...

You can check the guidance here as published by the Ministry of Finance: https://www.mof.gov.cy/mof/TAX/taxd...4/$file/Guidance for GHS 2023.pdf?OpenElement All financial institutions need to report under CRS and FATCA and as such the tax office would be aware that you have an active brokerage...

Hello In order to apply for the Certificate from the Cyprus Tax Department, the below documents are required: Tax returns for the year applying for a TRC Rental Agreement or a tittle deed of property (stamped by the Tax Department) Utility bill, EAC bill or Water Supply bill for the whole...

The exemption provided under 14(2) of the DTT requires that all requirements of the paragraph ((a)-(c)) are met. In your comments above you merely stated requirements subject to 14 (2) (a). Paragraph (b) for instance, mentions that the employer must not be a resident of the other State and (c) a...

We had just a couple of cases that the 2.5% IP Box regime was conceived by the foreign tax office as tax aggressive scheme and all related to German tax office. Of course, these cases were high profile clients involved in the energy and aviation sector. Yes, your understanding is correct...

Thank you for your kind words. We have assisted many clients with securing a tax rulling. The only downside and potential issue we faced so far was that certain group companies owning a Cyprus IP company implemented an aggressive scheme of re-charging expenses and recognising excessive royalty...

Thank you, just to clarify - I assume that the pre-approval you mention relates to the tax ruling application. If so, this is not mandatory and not required by law. However, it is the recommended course of action to make sure that the Tax Office will not challenge the tax status at a later...

First you need to examine whether the IP falls within the definition of qualifying assets of the Cyprus IP Box. Please explain what type of intellectual property you own or intend to develop so that we can advise. Happy to PM as well if you have specific questions

Please verify whether you sell digital services to consumers (B2C) or businesses (B2B). If it is the former, despite the fact that your company is registered in Switzerland, you will need to charge EU vat as the place of supply for Electronic/Digital services is where the consumer resides...

Yes your understanding is correct. Please see Tax Residency Certificate Application form https://www.mof.gov.cy/mof/TAX/taxd...82280036DC11/$file/TD 98_2015.pdf?OpenElement If any of the questions under Section C.2 raised in the application form is answered 'No' then the Tax office will not...

Appointment of a non-CY tax resident director is possible but this will denote that management and control of the Cyprus entity will be performed from abroad (where the Director will reside). My suggestion is to explore the 90 days rule and other personal income tax benefits (i.e. 50%...