CFC rules as a non-dom resident in cyprus

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BoomBoom

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May 28, 2025
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Hello, I was thinking about moving to Cyprus and becoming a non-dom tax resident there (plan to actually live there).
I wanted to open a Swiss company for trading crypto. Everything is legal and I don't try to avoid taxes or anything.
How strict are the CFC rules there, considering that there is no tax advantage of having a swiss company (there is banking advantages - almost impossible to have crypto business in cyprus with bank account)
Will the cyprus tax authority try to claim tax residency or something on the swiss company?
Also, how much taxes will I pay for dividends in this setup?

Thanks!
 
I had a similar question few weeks ago (UK limited, but the point is exactly yours, no tax advantage, just convenience).

The summary was that you need to establish substance for your company in the incorporation country otherwise the company will follow you. This seems not to be enforced practically, but if it does, even though Cyprus has lower CIT, it may become a complication of your tax affair as both countries may claim residency.
 
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