Cyprus CFC Rules 2026: No CFC for Individuals, and What That Does Not Mean

Status as of 30 October 2026: based on the Cyprus Income Tax Law 118(I)/2002 as amended, including its controlled foreign company rules introduced from 1 January 2019 under Council Directive (EU) 2016/1164 (ATAD) and the 2026 reform enacted by Law 244(I)/2025, the Special Defence Contribution Law 117(I)/2002 as amended by Law 245(I)/2025, Cyprus Tax Department Circular 1/2026 on low-tax jurisdictions, the German Foreign Tax Act (AStG) as published on gesetze-im-internet.de, the Romanian Fiscal Code, and the EU list of non-cooperative jurisdictions as revised by the Council on 9 October 2026. We will update this guide when the law or official practice changes.

The sentence travels fast. Someone posts it in a founders' group, someone else repeats it on a podcast, and by the time it reaches you it sounds like a key: "Cyprus has no CFC rules for individuals." You read it twice. You think of the company you already own abroad, the one in Delaware or Tallinn or Dubai, the profits sitting inside it, and you think: so I move to Cyprus, I keep that company, and nobody adds its profits to my income. Done.

Half of that is true. And the true half is valuable. Cyprus does not take the undistributed profits of a foreign company you own and tax them in your hands as an individual. Many European states do something very close to that, and Germany is the most famous example. For a founder, an investor or a family that holds shares, that difference is real money and real freedom.

The other half is where people get hurt. "No CFC for individuals" does not mean your company has stopped existing for tax purposes. It does not mean your old country has stopped watching. It does not mean a Cyprus company you put in the middle is outside the rules. And it certainly does not mean that nobody sees the structure. Those are the misunderstandings that turn a good move into a long letter from a tax office three years later.

For most of the last fifty years, the families who held companies across borders had someone to read the fine print for them. A private banker in Zurich, a law firm in London, a tax partner who knew which rule bit where. Everyone else heard the slogans. Until now only the rich could afford that kind of reading. Now you can too, with ENCC. This guide gives you the full picture: what Cyprus actually does with controlled foreign companies, what it gives you as an individual resident, the six things the rule does not mean, what Germany and Romania still check, and how we build a structure that holds when somebody finally looks.

The key points

• Cyprus CFC rules exist, but they apply to companies. Since 1 January 2019, Cyprus has controlled foreign company rules based on the EU Anti-Tax Avoidance Directive. They apply to Cyprus tax resident companies and to Cyprus permanent establishments of foreign companies. An individual who owns a foreign company directly is outside them.
• What that gives you. As a Cyprus tax resident individual, the undistributed profits of a foreign company you own are not attributed to you by Cyprus. Dividends you do receive are exempt from Cyprus income tax, and for Non-Doms the Special Defence Contribution is 0% SDC on dividends. GESY at 2.65% applies, capped.
• What it does not mean, in six points. Your company can still become Cyprus resident, or German or Romanian resident, through where it is managed. Your old country can still apply its own rules while you are resident there and, in Germany, for years after you leave. A Cyprus holding company is inside the Cyprus CFC rules. Payments out of Cyprus to low-tax jurisdictions now carry defensive taxes. The 2026 reform added new rules for domiciled residents. And banks, registers and tax authorities see the whole chain.
• The order matters. The rule works for people who move for real, plan the exit from their old country first and run their companies where they actually are.

Key terms, in plain words

Controlled foreign company (CFC). A company in another country that you, or your company, control, and whose profits are taxed low. CFC rules let the controlling country tax some of those profits before they are paid out.

Control. In the EU directive and in Cyprus law, more than 50% of the votes, capital or profit entitlement, held directly or indirectly, including through associated enterprises.

Low taxation. For Cyprus companies, a foreign subsidiary counts as low taxed if the tax it actually pays is less than half of what it would pay in Cyprus. With the Cyprus corporate rate at 15% from 2026, that means an effective rate below 7.5%, computed on Cyprus rules.

Non-genuine arrangement. An arrangement where the subsidiary owns assets or takes risks that are really decided and managed by people in the parent company. Cyprus applies its CFC rules only to income from such arrangements.

Place of effective management (PoEM). The place where the key management and commercial decisions of a company are actually taken. In Cyprus, a company managed and controlled on the island is Cyprus tax resident. Germany and Romania have their own versions of the same test.

Tax resident and domiciled. In Cyprus, you can be tax resident without being domiciled. Non-Doms do not pay the Special Defence Contribution on dividends and interest until they have been resident for 17 of the last 20 years.

Associated company. For the new Cyprus defensive measures, a company linked to the payer by control or significant ownership. These measures tax certain payments to associated companies in listed jurisdictions.

What the Cyprus law actually says

The rule protects the Cyprus tax base from Cyprus companies that park profits elsewhere. It was never aimed at you as a person. The Anti-Tax Avoidance Directive of 2016 required every EU member state to have CFC rules for corporate taxpayers from 2019. Cyprus transposed it into its Income Tax Law with effect from 1 January 2019. The directive speaks of taxpayers subject to corporate tax, and Cyprus did not extend the rules beyond that.

The scope is therefore narrow. The Cyprus CFC rules apply when:

• The taxpayer is a Cyprus company. A company tax resident in Cyprus, or a foreign company with a permanent establishment in Cyprus, holds the foreign entity.
• There is control. The Cyprus company, alone or with associated enterprises, holds more than 50% of the votes or capital, or is entitled to more than 50% of the profits.
• The foreign entity is low taxed. The actual corporate tax paid abroad is lower than the difference between the tax it would have paid in Cyprus and the tax actually paid. With the 2026 rate of 15%, the practical line is an effective foreign tax below 7.5%.

Cyprus chose the narrower of the two models the directive allows. Under its rules, only the undistributed income of the foreign company that arises from non-genuine arrangements is added to the Cyprus parent's income. The test is functional: which assets and risks of the subsidiary are really managed by significant people functions in the Cyprus company? If the people who decide sit in Cyprus, the profit that flows from those decisions is taxed in Cyprus. If the subsidiary has its own people taking its own decisions, the rule does not bite.

There are two exemptions for small cases. A foreign subsidiary is outside the rules if its accounting profits do not exceed EUR 750,000 and its non-trading income does not exceed EUR 75,000, or if its accounting profits are no more than 10% of its operating costs for the period. Where income is added, tax paid abroad is credited.

Individuals are not on the list. A Cyprus tax resident person who owns shares in a company in the United States, Estonia, the United Arab Emirates or anywhere else is not a corporate taxpayer, and the CFC chapter does not apply to them. Cyprus has no separate rule that adds a foreign company's retained profits to an individual's income. That is what the slogan means, and it is accurate.

What it gives you as a Cyprus resident

Profits can grow inside the company, and Cyprus does not tax you on money you have not received. For a founder this is the difference between building and being skimmed. Your company can reinvest, hire, hold reserves, buy a competitor, and Cyprus does not treat that as your income.

When you do take dividends, Cyprus treats them gently, if you are Non-Dom. Dividends are exempt from Cyprus income tax. The Special Defence Contribution is the tax that applies to dividends for domiciled residents, and since 2026 its rate on dividends for them is 5%. Dividends paid within six years from profits of tax years up to 2025 still bear 17%. For Non-Doms it is 0% SDC on dividends, and the same holds for interest, until you have been Cyprus resident for 17 of the last 20 years. GESY, the national health contribution, applies to dividends at 2.65%, within the annual income cap of EUR 180,000.

Residence is something you can reach in two ways. Cyprus treats you as tax resident if you spend more than 183 days there in the tax year, or under the 60-day rule if you spend at least 60 days there, do not spend more than 183 days in any other single state, keep a permanent home in Cyprus and carry on a business, are employed or hold an office with a Cyprus resident company during the year. Our guide on Cyprus tax residency and Non-Dom explains who each route suits, and Non-Dom dividends and SDC goes through the numbers.

This is what the wealthy have had for decades: a home base that lets capital work before it is touched. Now it is available to a software founder with one company and a family with one portfolio. But only if the rest of the picture is built right. Which brings us to what the sentence does not say.

What it does not mean, part one: that your company stops being somewhere

A company is tax resident where it is really run. Cyprus can make it Cypriot, and so can your old country. This is the point most often missed. If you live in Cyprus and you take every decision for your Delaware LLC or your Estonian OÜ from your desk in Larnaca, the company may well be managed and controlled in Cyprus. Then it is a Cyprus tax resident company, with 15% corporate tax on its profits. Since 1 January 2026, a company incorporated in Cyprus, or one that has moved its registered office to Cyprus, is also treated as Cyprus resident unless a double tax treaty provides otherwise.

That outcome is often not a problem. It can even be the best answer: a company properly resident in Cyprus, with Cyprus substance, paying 15% and distributing dividends to you as a Non-Dom at 0% SDC. It is a structure that banks understand and auditors can sign. The problem is only when you believe the company is somewhere else and it is not.

The reverse is worse. If you have moved to Cyprus but your company is still run from Munich, from Cluj or by a business partner in Vienna, those countries can claim the company is resident there. Germany looks at the centre of top management under § 10 of its Fiscal Code. Romania treats a foreign legal person with its place of effective management in Romania as Romanian. Austria has its own test. A company that is taxed where it is really managed is the norm, not the exception, and no CFC slogan changes it. Our guide on the place of effective management shows how the test is applied in practice.

What it does not mean, part two: that your old country has let go

Cyprus decides how Cyprus taxes you. It does not decide how Germany or Romania taxes you. CFC rules are national. While you are still resident in your old country, its rules apply to your foreign companies in full, whatever Cyprus does. And some countries keep a hand on you after you leave.

Germany is the strictest example. Its Foreign Tax Act contains a CFC regime in §§ 7 to 14. If persons subject to unlimited German tax control a foreign company, and that company earns passive income taxed below 15%, the income is added to the German shareholder's taxable income each year, distributed or not. For a company in an EU or EEA state, the shareholder can escape the addition by showing that the company carries on a genuine economic activity there with its own staff and premises.

Germany also follows you out of the door:

• Exit tax under § 6 AStG. If you hold at least 1% in a corporation and you have been subject to unlimited tax for at least seven of the last twelve years, your move abroad is treated as a sale of those shares at market value. The tax can be paid in seven annual instalments on application, usually against security. We plan this before the move, not after. Our guide on German exit tax and the year-end move explains the timing.
• Extended limited tax liability under § 2 AStG. German citizens who were subject to unlimited tax for at least five of the last ten years and move to a country with low taxation, while keeping essential economic interests in Germany, can remain subject to an extended German tax liability for up to ten years. The law treats a country as low taxed when it applies a preferential regime to the person. Whether a Cyprus Non-Dom position counts as such a regime is something we check for your case before you move, never assume.
• Interposed companies under § 5 AStG. For people within § 2, income of a foreign company they control can be attributed to them. In other words, Germany has a CFC rule for individuals who have left under certain conditions, exactly the thing people think they have escaped.

Romania works differently, but it also works. Romania taxes its residents on worldwide income. While you remain Romanian tax resident, based on your domicile, your centre of vital interests or more than 183 days in Romania within any twelve months, dividends from your foreign company are taxable in Romania at 16% from 2026, and CASS can apply above the legal thresholds. Romania's own CFC rule, in articolul 40⁵ of the Fiscal Code, applies to Romanian corporate taxpayers that control a foreign entity, not to an individual holding a foreign company directly. But a Romanian SRL that holds your foreign company can fall within it. And a foreign company with its place of effective management in Romania is a Romanian taxpayer.

So "no CFC for individuals" describes what Cyprus does after you have become Cyprus resident. It says nothing about what your old country does before, during and, for Germany, after the move.

What it does not mean, part three: that a Cyprus holding company is outside CFC

The moment you put a Cyprus company between you and your foreign subsidiaries, you are back inside the Cyprus CFC rules. This is the structure many founders want: a Cyprus holding company owning an operating company in the UAE, the United States or Asia. It can be very good. But the Cyprus holding is a corporate taxpayer, and if it controls a foreign company taxed below the 7.5% line, the Cyprus CFC rules apply to it.

Whether they bite depends on substance and on the small-case exemptions. If the foreign subsidiary has its own people taking its own decisions, there is no non-genuine arrangement and no addition. If the subsidiary is managed in practice by the people in Cyprus, the Cyprus company may be taxed on the subsidiary's undistributed profits that come from those decisions. And at that point the subsidiary may already be Cyprus resident under the PoEM test anyway.

The honest conclusion is simple. For many people the strongest version is not a chain but a single company: a Cyprus company with real management on the island, paying 15% corporate tax, with dividends to you as a Non-Dom. Where a foreign subsidiary is needed, for a licence, a market or a team abroad, we build it with its own decision-makers from the start.

What it does not mean, part four: that money leaves Cyprus without questions

Since 2026, Cyprus taxes certain payments to associated companies in low-tax and EU-listed jurisdictions. These defensive measures came from Cyprus's commitments under its Recovery and Resilience Plan and were rewritten by the 2026 reform. Under the Special Defence Contribution Law as amended by Law 245(I)/2025, dividends paid by a Cyprus company to an associated company resident in a jurisdiction on the Cyprus list of low-tax jurisdictions (Circular 1/2026) bear 5% withholding. Dividends and interest paid to associated companies in jurisdictions on the EU list of non-cooperative jurisdictions bear 17%. Interest and royalties paid to associated companies in low-tax jurisdictions can no longer be deducted.

The Cyprus list for 2026, set by Tax Department Circular 1/2026, contains Anguilla, the Bahamas, Bahrain, Bermuda, the British Virgin Islands, the Cayman Islands, Guernsey, the Isle of Man, Jersey, the Turks and Caicos Islands and Vanuatu. The EU list was revised on 9 October 2026, when Panama and Viet Nam were removed from Annex I. These rules hit companies, not you as an individual. But if your plan was a Cyprus company owned by a BVI or Jersey company, it now has a price. Our guide on the Cyprus low-tax jurisdictions list goes through the details.

What it does not mean, part five: that the 2026 reform passed you by

The 2026 reform made Cyprus better for most people, and it also closed doors that some planned to walk through. Law 244(I)/2025 and the related laws, including Law 245(I)/2025 for the SDC and deemed dividend changes, published on 31 December 2025, raised the corporate rate to 15%, lowered the SDC on dividends for domiciled residents from 17% to 5%, and abolished the old deemed dividend distribution for profits earned from 2026. Profits from 2024 and 2025 still fall under transitional rules for Cyprus resident and domiciled shareholders. Dividends paid within six years from profits of tax years up to 2025 still bear 17%.

For domiciled residents, the reform also introduced a rule on disguised dividends. Where a company gives value to its shareholder in a form that is a distribution in substance, for example through certain loans or benefits, the law can treat it as a dividend and tax it. The rule targets residents who are also Cyprus domiciled. A Non-Dom does not fall within it, but a Non-Dom becomes deemed domiciled after 17 of 20 years, and families with Cypriot roots may be domiciled from day one.

The message: Cyprus has no CFC rule for individuals, and it does have a rule for value taken out of a company by domiciled individuals. If you are Non-Dom, your position is clear. If you are not, the planning is different, and we tell you which side you are on before anything else.

What it does not mean, part six: that nobody sees it

A structure that works only if nobody looks is not a structure; it is a hope. Banks report financial accounts under the OECD Common Reporting Standard to the country where you are tax resident. EU states exchange information on cross-border arrangements and on beneficial owners. Company registers in the EU and in many other states record who owns what. The German, Romanian and Cypriot tax authorities exchange information under the EU directive on administrative cooperation and under their treaties.

None of this is a threat to a well-built plan. It is the reason why a well-built plan matters. We build structures that you can explain in one paragraph to a bank officer and defend in one file to a tax inspector. That is the difference between the private client of a large family office and the man who heard a slogan.

If you live in Germany: what the tax office checks

Before you leave, the German tax office checks your residence and your shares. After you leave, it checks whether you really left. The points we review with your German adviser:

• The end of unlimited liability. Under § 8 and § 9 of the Fiscal Code, a home you keep available in Germany, or a habitual abode there, keeps you unlimited taxable. Deregistration alone does not end it.
• Exit tax. Shares of at least 1% in any corporation, German or foreign, including a company you plan to hold from Cyprus, can trigger § 6 AStG on departure.
• CFC while you are still resident. Until the day you leave, a foreign company you control with passive income taxed below 15% can trigger the § 7 addition. Many founders discover it in the year of the move.
• § 2 and § 5 AStG after the move. Your citizenship, your remaining German interests and whether your new position is a preferential regime decide whether Germany keeps a claim for ten years.
• The treaty. Germany and Cyprus have a double tax treaty from 2011. It allocates taxing rights once residence is clear. It does not decide residence on its own; that is a matter of facts.

Our guide on moving from Germany to Cyprus step by step puts these points in order.

If you live in Romania: what ANAF checks

ANAF checks whether you are still Romanian resident and where your companies are really managed. The points we review with your Romanian adviser:

• Your residence. Domicile in Romania, the centre of vital interests or more than 183 days within twelve months keep you Romanian resident. Moving to Cyprus is documented with a Cyprus tax residence certificate and with the form ANAF uses for persons leaving Romania.
• Your companies. A Romanian SRL run from Cyprus stays Romanian. A Cyprus or other foreign company run from Romania can become Romanian through its place of effective management.
• Articolul 40⁵. If a Romanian SRL owns a low-taxed foreign company, Romania's CFC rule can apply at SRL level. If you own the foreign company directly as an individual, it does not.
• Dividends during the transition. Dividends received while you are still Romanian resident are taxed in Romania at 16% from 2026. Timing the move before the distribution is part of the plan.

How we do it: the order of steps

The rule is a tool. The order of steps is what makes it work. This is the sequence we follow with clients:

1. Map what you own. Every company, every share, every account, every country, who controls what and who decides what. One page.
2. Read the home-country rules for your case. With a licensed adviser in Germany, Romania or Austria: exit tax, CFC while still resident, extended liability after the move, dividend timing.
3. Choose the shape. Direct ownership of a foreign company, a Cyprus company with real substance, or a Cyprus holding with a foreign subsidiary that has its own management. We show the cost and the risk of each.
4. Build the Cyprus side. Residence by 183 days or by the 60-day rule, a home, registration with the Tax Department, the Non-Dom position, and, where chosen, a Cyprus company with real management and an office.
5. Move the decisions. Board meetings, signing, bank mandates and the people who decide sit where the company is supposed to be resident. We document it.
6. Leave the old country cleanly. Deregistration, notices to the tax office, the residence certificate from Cyprus, the timing of dividends and of share transfers.
7. Report everything correctly. Bank forms, CRS self-certifications, beneficial owner registers and annual returns in every country involved.
8. Review every year. Lists change, laws change, your life changes. We revisit the structure each year.

The most common mistakes

• Reading the slogan as a structure. "No CFC for individuals" is one rule in one country. It needs five other rules to be checked before it means anything for you.
• Keeping the decisions at home. Moving yourself to Cyprus while your company is still run from Germany or Romania by you, a partner or an employee who takes the real decisions.
• Forgetting exit tax. Leaving Germany with a valuable shareholding without calculating § 6 AStG first.
• Putting a Cyprus holding on top without substance. Then the Cyprus CFC rules or the PoEM test can bring the subsidiary's profits into Cyprus anyway.
• Using a low-tax parent. A BVI or Jersey company above a Cyprus company now attracts the defensive measures.
• Assuming Non-Dom. Domicile is a fact, not a choice. Cypriot roots, or 17 of 20 years in Cyprus, change it.
• Distributing before leaving. A large dividend taken in the last months of Romanian or German residence is taxed there.

Three illustrations

These are illustrations built for this guide, not real clients.

The founder with a US LLC. A software founder from Stuttgart owns a US LLC that sells subscriptions worldwide. He moves to Limassol in March. We first look at German exit tax on any corporate shares he holds, then at how the LLC is treated in Germany, Cyprus and the United States, because a transparent LLC is not a CFC case at all, it is a question of whose income it is. We conclude that a Cyprus company with real management on the island, owning the business, gives him one clear answer for banks and tax offices. He pays 15% corporate tax in Cyprus and takes dividends as a Non-Dom.

The investor with a Romanian SRL. An investor from Bucharest holds a Romanian SRL that owns 100% of a company in the United Arab Emirates. While she is Romanian resident, articolul 40⁵ can apply at SRL level. After she moves to Cyprus and the UAE company is run by its own team in Dubai, the picture changes: she owns the UAE company directly, Cyprus has no CFC rule for her as an individual, and the dividends she takes are exempt from Cyprus income tax with 0% SDC as a Non-Dom. Her Romanian SRL keeps its own Romanian obligations for whatever it continues to do.

The couple who wanted a chain. A couple from Vienna planned a BVI company above a Cyprus company above an operating company in Asia. We showed them that the BVI layer now costs 5% on dividends out of Cyprus and adds nothing, and that the Cyprus company would be inside the Cyprus CFC rules if the Asian company were run from Limassol. They chose a shorter chain, with the Asian company managed by its own directors, and moved to Cyprus themselves.

The circle you join

People who used to need a family office now need a plan and a partner who reads the fine print. Our clients are founders, freelancers, investors and families who earned what they have and want to keep the right to decide what to do with it. They are not looking to hide; they are looking to choose. Cyprus gives them an EU base, a 15% corporate rate, and for Non-Doms 0% SDC on dividends. We give them the order of steps, the licensed partners and the discipline that make it last. Read how others combine the pieces in our guide on Cyprus as your EU base and Plan B.

FAQ

Does Cyprus have CFC rules?

Yes, since 1 January 2019, for Cyprus tax resident companies and Cyprus permanent establishments of foreign companies. They apply to income from non-genuine arrangements of low-taxed foreign subsidiaries controlled by the Cyprus company.

Do the Cyprus CFC rules apply to individuals?

No. An individual Cyprus tax resident who owns a foreign company directly is not within them, and Cyprus has no other rule that adds the foreign company's retained profits to the individual's income.

So I can keep my foreign company and pay nothing until I distribute?

In Cyprus, the retained profits are not taxed in your hands. But the company is taxed where it is resident, and it may be resident in Cyprus if you run it from Cyprus, or in your old country if it is still run from there. Your old country's rules apply until you have really left, and in Germany sometimes after.

What does "low taxed" mean for Cyprus companies in 2026?

An effective foreign tax that is less than half of the Cyprus tax on the same profits. With the 15% Cyprus rate, that is below 7.5%, computed on Cyprus rules.

Is a Cyprus holding company caught by its own CFC rules?

It can be, if it controls a low-taxed foreign subsidiary whose income comes from assets and risks really managed in Cyprus. Small subsidiaries under the EUR 750,000 and EUR 75,000 thresholds, or with profits no more than 10% of operating costs, are outside.

Does Germany still apply its CFC rules after I move to Cyprus?

The ordinary German CFC rules apply to persons subject to unlimited German tax. After you have really left, they stop applying to you. But § 5 AStG can attribute income of foreign companies to German citizens who fall under the extended limited liability of § 2 AStG, for up to ten years. That is the point most guides skip.

Does Romania have a CFC rule for individuals?

Romania's CFC rule in articolul 40⁵ of the Fiscal Code applies to corporate taxpayers. An individual who owns a foreign company directly is outside it, though a Romanian SRL that owns one can be within it, and a foreign company managed from Romania becomes a Romanian taxpayer.

Do Non-Doms pay anything on dividends in Cyprus?

0% SDC on dividends for Non-Doms, and dividends are exempt from Cyprus income tax. GESY applies at 2.65%, within the annual income cap. After 17 of 20 years of residence you become deemed domiciled.

Is this legal?

Yes. Choosing where you live and how you own your companies, and declaring everything correctly, is the most ordinary freedom you have. What the law punishes is pretending: a residence that is not real, a company that is managed somewhere other than declared. We build the real version.

Next steps

Write down three things: every company you own and where it is registered, who takes its decisions today, and when you plan to move. With that, one conversation shows whether "no CFC for individuals" helps you, and what must be done first so that it holds. For background, read our guides on relocating to Cyprus, forming a Cyprus company and the place of effective management.

Want the numbers on your own profit? Our Cyprus tax calculator shows what is left of every €100 between salary and dividends.

Sources

• Council Directive (EU) 2016/1164 (Anti-Tax Avoidance Directive), Articles 7 and 8, EUR-Lex: https://eur-lex.europa.eu/eli/dir/2016/1164/oj
• Cyprus Income Tax (Amending) (No. 4) Law 244(I)/2025 (CyLaw, Greek): https://www.cylaw.org/nomoi/arith/2025_1_244.pdf
• Law 245(I)/2025 amending the Special Defence Contribution Law (CyLaw, Greek): https://cylaw.org/nomoi/arith/2025_1_245.pdf
• Cyprus Tax Department, Circular 1/2026 and list of low-tax jurisdictions for 2026: https://www.gov.cy/mof-tax/en/documents/legislation-circulars-and-related-material-of-direct-taxation/dikaiodosies-me-chamilo-forologiko-syntelesti/
• Cyprus Ministry of Finance, tax incentives: https://www.gov.cy/mof/en/documents/tax-incentives/
• PwC Cyprus, Direct Tax Update 1/2026 on the tax reform: https://www.pwc.com.cy/en/publications/direct-tax-updates-2026/dtu-n1-2026.pdf
• German Foreign Tax Act (AStG), §§ 2, 5, 6, 7 and 8: https://www.gesetze-im-internet.de/astg/
• German Fiscal Code (AO), § 10: https://www.gesetze-im-internet.de/ao_1977/__10.html
• Council of the EU, EU list of non-cooperative jurisdictions: https://www.consilium.europa.eu/en/policies/eu-list-of-non-cooperative-jurisdictions/
• European Commission, Council updates the EU list, 9 October 2026: https://taxation-customs.ec.europa.eu/news/council-updates-eu-list-non-cooperative-tax-jurisdictions-cooperation-delivers-further-progress-2026-10-09_en
• ANAF, summary of 2026 tax changes: https://static.anaf.ro/static/10/Brasov/Brasov/modificari_fiscale_2026.pdf

Verified on 30 October 2026.

Cover photo: Paphos Castle at night, Cyprus. Photo by Punteador, Wikimedia Commons, CC BY-SA 4.0, cropped.