Cyprus Register of Ultimate Beneficial Owners

No later than mid-September, companies established before 16 March 2021 will have to have data on their ultimate owners entered in a special register

Requirements for the disclosure of the ultimate owners of Cypriot companies

Since this year, Cyprus has introduced requirements for the disclosure of the ultimate owners of Cypriot companies. No later than mid-September, companies established before 16 March 2021 will have to have data on their ultimate owners entered in a special register, while companies established after the specified date will have 30 days for the disclosure of their beneficiaries.

The KPMG Review attached in the pdf below analyses in detail the regulatory framework, provision of the UBO data to the Register, processing of the UBO information as well as provides recommendations to the business owners.

KPMG tax experts recommend

  • reviewing your structures for the presence of any Cypriot companies that are subject to the requirement to provide information about their UBOs to the Cyprus Register;
  • identifying a UBO (if the Cyprus company does not have such information at its disposal) and collecting the required information about the UBO;
  • obtaining an identification code through the Cyprus government portal Ariadne;
  • providing UBO data to the Register using the step-by-step instructions in the guidance within 6 months starting from 16 March for companies established before 16 March this year, or within 30 days from the date of registration for new companies;
  •  after the introduction of the permanent platform, updating and confirming UBO data annually in December.

Given that the Cyprus Register is to increase the transparency and accessibility of information on the ownership structures of Cypriot companies, their ultimate owners and affiliates, we also recommend reviewing the current structures to determine:

  • whether information about all Cypriot controlled companies is filed and whether data on their owners submitted to Russian tax authorities are correct
  • whether the tax benefits on payments to Cypriot companies are correctly applied – in particular, whether such companies are entitled to reduced withholding tax rates under the treaty between Russia and Cyprus
  • the extent of the risk that Cypriot companies will be recognized as Russian tax residents.

If such diagnostic assessment reveals significant tax risks, management decisions will need to be made on how to mitigate these risks and how to manage them in the future.