Place of Effective Management in Cyprus: The Complete 2026 Guide to Company Tax Residence

Status as of 22 October 2026: based on the Cyprus Income Tax Law 118(I)/2002 as amended by Law 244(I)/2025 (definition of "resident in the Republic" for companies and individuals, in force from 1 January 2026), the Special Defence Contribution Law as amended by Law 245(I)/2025, Cyprus's position under the OECD Multilateral Instrument, the OECD Model Tax Convention 2017 and its Commentary on Articles 4 and 5, HMRC's International Manual on company residence, the German Fiscal Code and Corporation Tax Act, the Austrian Federal Fiscal Code, the Italian Income Tax Code, and the Germany-Cyprus tax treaty of 2011. Rates and rules are those in force on this date. We will update this guide when the law or official practice changes.

A Cyprus company is not resident in Cyprus because it was registered there. It is resident where the law of each interested state says it is, and for a company owned by a person who lives or has lived elsewhere, at least two states will ask the question. Cyprus asks it through two statutory tests. The other state asks it through its own test, which almost always comes down to one issue: where the company is actually managed.

That issue decides whether the profit is taxed once, at the Cyprus corporate rate of 15%, and then distributed to a Cyprus tax resident Non-Dom with no SDC on dividends, or whether it is claimed by a second state, with corporate tax, trade tax, penalties and interest. The difference for an owner-managed company is rarely small. It is the difference between a structure that works and a structure that is a liability.

This guide is written for owners, finance directors and advisers who want the full picture. It sets out the statute, the case law that gives it meaning, the OECD rules that resolve conflicts between states, the way the tax authorities of the United Kingdom, Germany, Romania and other EU states actually build a residence challenge, the evidence that answers it, the role of substance and board practice, the errors we see most often, and a governance checklist. It is long because the subject deserves precision.

What this guide covers

1. The key points
2. Key terms defined
3. The Cyprus statute since 1 January 2026
4. Central management and control: the case law test
5. Place of effective management: the treaty test
6. The indicators tax authorities examine
7. How a home-country challenge is built: United Kingdom, Germany, Romania and other EU states
8. Dual residence and the treaty tie-breaker
9. Permanent establishment: the second line of attack
10. Substance in Cyprus
11. Board practice: meetings, minutes, video calls and written resolutions
12. The governance file: documents and evidence
13. Step by step: moving the management of a company to Cyprus
14. The most common errors
15. Worked examples
16. Checklist and FAQ

The key points

• Two statutory tests in Cyprus since 2026. A company is Cyprus resident if its management and control is exercised in Cyprus, or if it is incorporated or registered in Cyprus, unless a tax treaty provides otherwise.
• Management decides abroad. Foreign tax authorities look at where the key strategic and commercial decisions are actually taken, not at the registered office.
• Treaties settle conflicts. When two states both claim a company, the treaty tie-breaker decides. Cyprus has reserved its right not to apply the Multilateral Instrument's article on dual-resident companies, so its existing tie-breakers stay in force.
• The owner's residence is usually the deciding fact. For an owner-managed company, the place where the owner lives and decides tends to become the place of management.
• Permanent establishment is a separate risk. Even a company resident in Cyprus can be taxed abroad on profit attributable to a fixed place of business there, including, in some cases, a home office.
• The result of correct design: profit taxed at 15% in Cyprus and dividends to a Cyprus tax resident Non-Dom with no SDC on dividends, with the GESY health contribution on the dividend capped.

Key terms defined

Tax residence of a company. The state that may tax the company on its worldwide profit. Every state defines it for itself.

Management and control. The Cyprus statutory concept, interpreted through English and Cypriot case law as the place where the highest level of control over the company's business is actually exercised.

Central management and control. The case law formulation of that concept, as applied in the United Kingdom and in common law jurisdictions.

Place of effective management. The treaty concept used in the OECD Model and in many Cyprus treaties to decide the residence of a company that both states claim. It refers to the place where the key management and commercial decisions necessary for the conduct of the business as a whole are in substance made.

Ort der Geschäftsleitung. The German concept under § 10 of the Fiscal Code: the centre of the company's top-level business management.

Permanent establishment. A fixed place of business through which the business of an enterprise is wholly or partly carried on. It allows a state to tax the profit attributable to that place, even if the company itself is resident elsewhere.

Dual residence. The situation in which two states each treat the same company as resident under their own law. It is resolved, if at all, by the treaty between them.

The Cyprus statute since 1 January 2026

The rule: Cyprus now treats a company as resident on either of two grounds. Law 244(I)/2025 rewrote the definition of "resident in the Republic" in the Income Tax Law with effect from 1 January 2026.

The first ground is the classic one: a company whose management and control is exercised in Cyprus. It applies regardless of where the company was incorporated, so a company formed in another jurisdiction but genuinely run from Cyprus can be Cyprus resident.

The second ground is new: a company incorporated or registered in Cyprus under the Companies Law is resident, unless a double tax treaty provides otherwise. A company that has moved its registered office or seat to Cyprus is treated in the same way.

For a company that is genuinely run from Cyprus, the change adds a second anchor and changes nothing in practice. For a Cyprus company run from somewhere else, it changes a great deal. Before 2026, such a company could fall outside Cyprus residence altogether. Now Cyprus claims it by incorporation while the other state claims it by management. The company is dual resident, may have filing obligations in both states and has to rely on the treaty. That is a cost and a risk, not a shelter.

The corporate tax rate is 15% from 1 January 2026. The Special Defence Contribution Law, as amended by Law 245(I)/2025, continues to apply SDC only to individuals who are both Cyprus tax resident and Cyprus domiciled, which is why a Cyprus tax resident Non-Dom receives dividends with no SDC on dividends. The GESY health contribution of 2.65% applies to dividends up to the annual income cap of EUR 180,000.

Central management and control: the case law test

The core principle: a company resides where its real business is directed, not where its documents are filed. The Cyprus statute does not define "management and control". Cyprus, whose legal tradition derives from English law, reads it through case law.

The leading formulation comes from the English House of Lords in De Beers Consolidated Mines v Howe in 1906: a company resides where its real business is carried on, and the real business is carried on where the central management and control actually abides. More than a century later, that sentence remains the centre of the test.

Later English cases refined it, and HMRC's International Manual summarises them. Three propositions matter in practice.

First, central management and control is a question of fact. It is found by looking at what actually happened, not at what the constitution or the minutes say should have happened.

Second, it usually sits with the board of directors, but not always. If the board is bypassed and the real decisions are taken by someone else, typically a dominant shareholder, the place where that person decides can become the place of central management and control.

Third, a board that genuinely considers and takes decisions keeps control even if it is influenced by a shareholder or a parent company. In Wood v Holden in 2006, the English Court of Appeal accepted that a board which actually took the decision, even though the transaction had been designed by advisers acting for the shareholders, exercised central management and control where it met. The distinction drawn is between a board that decides, however much it is advised, and a board that merely signs what has already been decided elsewhere.

That distinction is the practical heart of the subject. It explains why some Cyprus structures withstand scrutiny for decades and why others collapse at the first enquiry.

Place of effective management: the treaty test

Treaties use a close relative of the case law test: the place of effective management. It matters when two states both treat the same company as resident.

The OECD Commentary has long described the place of effective management as the place where the key management and commercial decisions necessary for the conduct of the entity's business as a whole are in substance made. The words "in substance" carry the weight. Tax authorities look through formalities to the reality.

Since the 2017 update of the OECD Model, the standard tie-breaker in new treaties no longer applies the place of effective management automatically. Instead, the two tax authorities try to agree on a single residence by mutual agreement, having regard to the place of effective management, the place of incorporation and any other relevant factors. The 2017 Commentary on Article 4 lists the factors they would normally consider, among them where the board meets, where the chief executive and other senior executives usually carry on their activities, where the senior day-to-day management is carried on, where the headquarters are located, which state's law governs the company's legal status, and where the accounting records are kept.

Read together, the case law and the OECD factors point in one direction. A structure is defensible when the people who direct the company, the meetings at which they direct it, the executives who implement it and the records that document it are in the same place.

The indicators tax authorities examine

Each indicator can be designed and documented in advance, rather than reconstructed under audit. No single indicator decides the question. Taken together, they show where the company is run.

• Composition of the board. Where the directors live, what they know, and whether they are genuinely capable of directing the business. A board resident in Cyprus and competent in the company's field points to Cyprus.
• Place and quality of board meetings. Regular meetings in Cyprus, with the directors physically present, a real agenda, papers circulated in advance and recorded discussion.
• Location of strategic decisions. Budget approval, entering or leaving markets, major contracts, borrowing, investment, dividends and senior appointments.
• Negotiation and signature of key contracts. Who negotiates, who signs, and where.
• Control of money. Bank mandates, payment approval rights, online banking access and the location from which payments are authorised.
• Senior day-to-day management. Where the chief executive or managing director actually works.
• Books and records. Where the accounts, statutory registers and minute book are kept and maintained.
• Premises. An office or serviced workspace in Cyprus that the company actually uses.
• Correspondence. Emails, messages and calendars, which in a modern audit are often the most revealing evidence of where decisions originate.

None of this requires a large operation. A one-person consultancy can satisfy every indicator, provided the person lives in Cyprus and runs the company from there. A larger group can satisfy it through a genuinely independent board based in Cyprus with real decision-making authority.

How a home-country challenge is built

Every residence challenge follows the same logic: the authority looks for the person who really decides, and then for where that person was. The legal labels differ; the method does not. Understanding the method is the best way to design against it.

United Kingdom

A company is UK resident if it is incorporated in the UK or if its central management and control is exercised in the UK. HMRC's International Manual sets out the case law and the approach. In a typical enquiry HMRC asks who the directors are and where they live, reviews board minutes, examines whether the board actually considered the decisions it recorded, and may request emails and correspondence to trace where proposals were formulated and approved. A Cyprus company whose owner-director runs it from London is, in the ordinary case, UK resident under domestic law. The UK-Cyprus treaty of 2018 then leaves the final residence to agreement between the two tax authorities, and until they agree, the company cannot claim most treaty benefits.

Germany

Under § 1 of the Corporation Tax Act, a company with its management or its seat in Germany is subject to unlimited German corporate tax. § 10 of the Fiscal Code defines the place of management as the centre of top-level business management. German practice looks for the place where the person entitled to manage the company forms the decisive will on day-to-day management of importance, and that place can be a private home or a home office. A German tax audit typically asks where the managing director lives, where he works on most days, where the signing authority over bank accounts is exercised, and whether the foreign board exercises real functions or merely executes instructions from Germany. If management is found in Germany, the company is also exposed to trade tax. Under Article 4(3) of the Germany-Cyprus treaty of 2011, the place of effective management decides the residence of a dual-resident company. German readers should also consider the controlled foreign company rules in §§ 7 and 8 of the Foreign Tax Act and the exit taxation of shareholdings under § 6, discussed below.

Romania

Under Article 7 point 18 of the Romanian Fiscal Code, a foreign legal person is treated as having its place of effective management in Romania if its economic and strategic decisions are taken in Romania, or if at least 50% of its directors are Romanian residents, unless shown otherwise. Article 8^1 sets out how the Romanian tax authority establishes that residence and refers conflicts to the applicable treaty. The 50% rule is unusually mechanical: a Cyprus company with two directors, one of whom lives in Romania, already reaches the threshold. Romanian readers will find a detailed treatment in the Romanian version of this guide.

Austria, Italy and other EU states

The pattern repeats across Europe. Austria's Federal Fiscal Code, § 27, locates a company's place of management at the centre of its top-level business management, a formulation close to the German one. Italy's Income Tax Code, Article 73, as amended from 2024, treats a company as resident if, for most of the tax period, it has in Italy its registered office, its place of effective management or its principal day-to-day management. Most other EU states apply some combination of incorporation and place of management. The details differ. The method is the same: find the decision-maker, find where he decides.

For every reader, the defensive answer is the same: change the facts, not the paperwork. ENCC plans the move, the board and the documentation in one sequence. Book a consultation.

Dual residence and the treaty tie-breaker

When two states both claim the company, the treaty decides, and the wording of each treaty matters.

Cyprus has a wide treaty network. Two families of tie-breaker matter in practice.

The classic rule, found in many older Cyprus treaties, deems a dual-resident company to be resident only in the state where its place of effective management is situated. The Germany-Cyprus treaty of 2011 uses this rule in Article 4(3). Under such a treaty, a company whose effective management is genuinely in Cyprus is Cyprus resident for treaty purposes, even if the other state's domestic law also claims it.

The newer rule, reflected in the 2017 OECD Model and in the 2018 treaty between Cyprus and the United Kingdom, asks the two tax authorities to agree on a single residence case by case. Until they agree, the company is generally not entitled to most treaty relief. This is a slower and less predictable route, which makes good design before the fact even more valuable.

The OECD Multilateral Instrument offers states an option to replace existing company tie-breakers with that case-by-case approach. Cyprus reserved its right not to apply that article. Cyprus's existing tie-breakers therefore stay as they are, and where a Cyprus treaty uses the place of effective management, that test still decides.

For a properly built structure, this is the favourable outcome. With the board, the decisions, the executives and the records in Cyprus, the tie-breaker points to Cyprus.

Permanent establishment: the second line of attack

Even where residence is secure, a state can still tax profit attributable to a fixed place of business on its territory. Advisers who focus only on residence often overlook this.

Under Article 5 of the OECD Model, a permanent establishment is a fixed place of business through which the business of an enterprise is wholly or partly carried on. The 2017 OECD Commentary explains that a home office can constitute a permanent establishment where it is used on a continuous basis for the enterprise's business and the enterprise requires the individual to use it, for example because no other office is made available. Occasional work from home does not normally create one.

For an owner who has moved to Cyprus but still spends substantial working time in his former country, or for a team member who works for the Cyprus company from another state, the risk is real. The answer is the same as for residence: organise the work so that the business is carried on in Cyprus, and where people genuinely work abroad, contract their services through properly priced arrangements in their own state.

Substance in Cyprus

Substance is the visible proof that management in Cyprus is real. It is not a fixed list. It is proportionate to the business.

For a holding company, substance can be modest: a competent board resident in Cyprus, regular meetings on the island, accounting and corporate administration in Cyprus, and decisions on investments and dividends taken there. For an operating company, it usually includes premises, a managing director who works from Cyprus and, as the business grows, local staff.

Substance serves three purposes at once. It supports Cyprus residence under the management and control test. It supports the place of effective management under a treaty. And it supports the application for a Cyprus tax residence certificate, which the professionals preparing the file must be able to justify by showing where management and control is exercised.

Board practice: meetings, minutes, video calls and written resolutions

Good board practice converts a legal requirement into a routine.

Meetings. Hold regular board meetings in Cyprus, at least quarterly for an active company, with additional meetings for significant decisions. Directors should attend in person in Cyprus whenever possible.

Papers. Circulate an agenda and supporting papers in advance: management accounts, proposals, risk notes. A board that receives information can deliberate. A board that receives only a resolution to sign cannot.

Minutes. Record who attended and where, what was presented, what was discussed, what was decided and why. Minutes that show deliberation carry weight. Minutes that say only "approved" carry little.

Video calls. The law has not banned them. What matters is where the directors physically are when the decision is taken. A board that meets by video while its directors sit in Cyprus is far easier to defend as deciding in Cyprus; directors dialling in from abroad weaken that picture.

Written resolutions. Where the articles allow them, record where each director signs. A resolution signed by all directors in Cyprus supports the picture; one signed abroad does not.

Delegation. If day-to-day authority is delegated to a managing director, the delegation should be documented, and the managing director should exercise it from Cyprus.

Travel. Plan the board calendar around the directors' days on the island and keep a travel log. It serves both the company's management file and each individual's own day count.

The governance file: documents and evidence

A governance file is the company's answer to an enquiry, prepared before the enquiry arrives. It should contain at least the following.

• Certificate of incorporation, memorandum and articles, and any shareholder agreements.
• Register of directors, with evidence of each director's residence and qualifications.
• Board calendar, agendas, papers and signed minutes, with attendance and location recorded.
• Written resolutions with the place of signature noted.
• Delegations of authority and signing policies.
• Bank mandates and records showing from where payments were approved.
• Office lease or serviced office agreement, and evidence of use.
• Accounting records, statutory registers and the minute book, kept in Cyprus.
• Key contracts, with place of negotiation and signature where relevant.
• Travel logs of directors.
• Cyprus tax residence certificates, once issued.
• For owners who have relocated: evidence of personal residence in Cyprus, such as a lease, utility bills and the individual's own tax residence certificate.

Keep the file current. Evidence assembled in real time is credible. Evidence assembled after a letter from a tax office is not.

Step by step: moving the management of a company to Cyprus

1. Decide where the decision-makers will live. Everything follows from this. For an owner-managed company, it usually means the owner's own relocation. Our 60-day rule calendar explains how the individual becomes Cyprus tax resident.
2. Review the exit side. Before any change, a tax adviser in the current country reviews exit taxes on shareholdings, the transfer of functions or assets, and the timing of departure. Our guide to German exit tax at year end shows why timing matters.
3. Choose the vehicle. A new Cyprus company, or the migration of an existing company where corporate law permits it. Each has different exit consequences at home.
4. Design the board. Directors resident in Cyprus and capable of directing the business. For a relocated owner, that is usually the owner and, often, a second director who brings real expertise. Every director must actually take part in decisions.
5. Set the governance framework. Board calendar, information flows, delegation of authority, signing policy and minute templates.
6. Align money and contracts. Bank mandates and payment approvals held by directors in Cyprus; key contracts negotiated and signed there.
7. Establish premises and records. Office or serviced workspace; accounts, registers and minute book maintained in Cyprus.
8. Hold the first board meeting in person in Cyprus. Minute the adoption of the governance framework and the first strategic decisions.
9. Apply for the tax residence certificate when the facts support it.
10. Review annually. Before each financial year, compare the facts with the file and correct gaps before they become evidence.

ENCC coordinates every step with licensed Cyprus lawyers, accountants and corporate service providers. Book a consultation.

The most common errors

• The decorative director. A local director who signs whatever arrives does not move management. Tax authorities ask who decides, not who signs. ENCC does not arrange such setups.
• Decisions by email from abroad. Board meetings in Cyprus while the real decisions are made in messages sent from another country. Correspondence is evidence, and it shows where decisions came from.
• All financial control abroad. If the only person with banking authority lives elsewhere, the money trail points to that person.
• The split board. Half the directors in the owner's home country. Under Romanian law, 50% is already the threshold.
• The retained home. For the owner, a home kept available in the former country can keep the individual resident there, and with him the management of the company.
• Ignoring permanent establishment. Working for the Cyprus company from a home office abroad on a continuous basis.
• Forgetting the exit. Moving management, or oneself, can trigger exit taxation in the former country. Plan it before, not after.

Worked examples

These cases are illustrations, not clients, and the figures are simplified.

A software consultancy that followed its owner

A UK-resident founder runs a software consultancy through a UK company. A Cyprus company run from Manchester would be UK resident under domestic law, so he plans a genuine move. He rents a flat in Larnaca, establishes a Cyprus company with himself and an experienced Cyprus-resident director on the board, opens banking with signing rights exercised in Cyprus and holds the first board meeting on the island. His UK accountant manages the wind-down of the UK company. From the following tax year he counts his days, holds his directorship and receives dividends as a Non-Dom.

Two founders in different countries

An e-commerce business has two founders. One moves to Cyprus; the other remains in Ireland. A board split between Ireland and Cyprus, with most commercial decisions approved from Dublin, would put management at risk of being located in Ireland. They restructure: the Cyprus founder and a Cyprus-resident chartered accountant form the board and take the strategic decisions in Cyprus. The Irish founder works through a small Irish service company that invoices the Cyprus company at arm's length. Each company's profit sits where its work and decisions are.

A holding company with a real board

An investor resident in Paphos since 2025 holds shares in three trading companies. He forms a Cyprus holding company with himself and a Cyprus-resident corporate lawyer as directors. Investment decisions, dividend policy and refinancing are decided at quarterly meetings in Nicosia, with papers prepared by the company's accountant. When he spends a month abroad, no decisions are taken there; the board meeting waits for his return.

What the result looks like

An illustration for 2026, before accounting costs and any exit tax in the former country:

• Company profit: EUR 200,000, earned by a company genuinely managed in Cyprus.
• Corporate tax at 15%: EUR 30,000. Retained: EUR 170,000.
• Dividend to a Cyprus tax resident Non-Dom: no SDC on dividends, plus GESY at 2.65% up to the annual cap of EUR 180,000, about EUR 4,505 on EUR 170,000.
• Net to the shareholder: about EUR 165,500.

Non-Dom status gives no SDC on dividends and interest until the individual has been Cyprus resident for 17 of the last 20 years. Our guide to Non-Dom dividends and no SDC explains the mechanism.

Further risks to plan for

• Controlled foreign company rules. Germany attributes certain passive income of a foreign company controlled by German residents if it is taxed at less than 15% (§§ 7 and 8 of the Foreign Tax Act). Cyprus's 15% rate is at that level, but special regimes can lower the effective rate, so a German adviser should review the case while the owner is still German resident. Romania has its own CFC rule in Article 40^5 of the Fiscal Code.
• Exit taxation. Germany can tax the latent gain on shareholdings of at least 1% when the holder leaves (§ 6 of the Foreign Tax Act). Other states have comparable rules.
• Cyprus tax residence certificate. Applications must be supported by evidence of where management and control is exercised.
• Personal residence and Non-Dom. The no-SDC treatment on dividends applies only to Cyprus tax resident Non-Doms. Days, home and Cyprus activity should be documented.

For a review of your own facts, book a consultation.

Practical checklist

• Directors: resident in Cyprus and capable of directing the business; none who merely signs.
• Board meetings: regular, in Cyprus, directors physically present, agenda and papers in advance.
• Strategic decisions: taken and minuted in Cyprus.
• Senior management: the managing director works from Cyprus.
• Contracts: key contracts negotiated and signed in Cyprus.
• Money: bank mandates and payment approvals held by directors in Cyprus.
• Records: accounts, registers and minute book kept in Cyprus.
• Premises: an office or serviced workspace actually used.
• Video and written resolutions: location of each director recorded.
• Permanent establishment: no continuous work for the company from a home office abroad.
• Exit: reviewed in advance by an adviser in the former country.
• Annual review: facts compared with the file, gaps corrected.

FAQ

Is a Cyprus company always Cyprus tax resident?

Since 1 January 2026, a company incorporated in Cyprus is Cyprus resident unless a tax treaty provides otherwise, and a company managed and controlled in Cyprus is resident wherever it was incorporated. If another state also claims the company because it is managed there, the treaty tie-breaker decides.

What is the difference between management and control and place of effective management?

Management and control is the Cyprus domestic concept, interpreted through case law. Place of effective management is the treaty concept used to resolve dual residence. In practice they look at the same facts: where the key decisions are actually made.

Can I hold board meetings by video?

Yes. What matters is where the directors physically are when they decide. When the directors are physically in Cyprus as they decide, the meeting supports management in Cyprus; each case is still judged on all the facts.

Can a local director solve the question?

Only if that director really manages the company, with the knowledge, information and authority to do so. A director who signs what is sent does not move management.

Can my home office abroad create a permanent establishment?

It can, if it is used on a continuous basis for the company's business and the company effectively requires its use. Occasional work from home does not normally create one.

Does the 60-day rule help my company?

The 60-day rule concerns individuals. One of its conditions can be met by holding an office in a Cyprus tax resident company, so a properly run company and the owner's personal residence support each other.

What happens if my home country also claims the company?

The company is dual resident and the treaty decides. Under the Germany-Cyprus treaty, the place of effective management decides. Under the UK-Cyprus treaty, the tax authorities agree case by case. Cyprus has not adopted the Multilateral Instrument's article on dual-resident companies.

Do I have to live in Cyprus?

For an owner-managed company, living in Cyprus is the most robust way to place management there. Larger groups can run a Cyprus company through a genuinely independent board resident in Cyprus. We assess which route fits your facts.

Next steps

For the arithmetic of keeping a Cyprus company while staying at home, read Cyprus company without residency. For the formalities of a one-director company, see our Cyprus Ltd sole director and secretary guide. For the personal side of the move, read leaving a high-tax country for Cyprus. Today's companion piece looks further east: Georgia's high net worth tax residence and Armenia as a second door. All our guides are on the English blog.

Sources

• Cyprus Income Tax Law 118(I)/2002, consolidated text (CyLaw, Greek): https://www.cylaw.org/nomoi/enop/non-ind/2002_1_118/full.html
• Law 244(I)/2025 amending the Income Tax Law, section 2 (definition of resident), in force 1 January 2026 (CyLaw, Greek): https://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 Ministry of Finance, list of double tax treaties: https://www.gov.cy/mof/en/documents/double-tax-treaties/
• OECD, MLI position of the Republic of Cyprus (reservation on Article 4): https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/beps-mli/beps-mli-position-cyprus-instrument-deposit.pdf
• OECD Model Tax Convention on Income and on Capital, condensed version 2017, Commentary on Articles 4 and 5: https://www.oecd.org/en/publications/model-tax-convention-on-income-and-on-capital-condensed-version-2017_mtc_cond-2017-en.html
• HMRC International Manual, company residence (INTM120000 onwards, including De Beers and Wood v Holden): https://www.gov.uk/hmrc-internal-manuals/international-manual/intm120000
• German Fiscal Code, § 10: https://www.gesetze-im-internet.de/ao_1977/__10.html
• German Corporation Tax Act, § 1: https://www.gesetze-im-internet.de/kstg_1977/__1.html
• German Foreign Tax Act, §§ 6, 7, 8: https://www.gesetze-im-internet.de/astg/
• Romanian Fiscal Code, Law 227/2015, Articles 7, 8^1 and 40^5 (ANAF): https://static.anaf.ro/static/10/Anaf/legislatie/Cod_fiscal_norme_2023.htm
• Austrian Federal Fiscal Code (BAO), § 27 (RIS): https://www.ris.bka.gv.at/NormDokument.wxe?Abfrage=Bundesnormen&Gesetzesnummer=10003940&Paragraf=27
• Italian Revenue Agency, Circular 20/E of 4 November 2024 on company residence under Article 73 TUIR as amended by Legislative Decree 209/2023: https://www.agenziaentrate.gov.it/portale/documents/20143/6519685/circolare%2Bn.%2B20%2Bde%2B4%2Bnovembre%2B2024%2Bresidenza%2Bpdf.pdf/978517e4-aa40-d14c-be79-19028c0f8785

Verified on 22 October 2026.

Cover photo: Limassol Castle, Cyprus. Photo: A.Savin, Wikimedia Commons, Free Art License, cropped.