Taxation of international executives
Tax returns and compliance
Termination of residence
Economic employer approach
Types of taxable compensation
Salary earned from working abroad
Taxation of investment income and capital gains
Additional capital gains tax (CGT) issues and exceptions
General deductions from income
Tax reimbursement methods
Calculation of estimates/prepayments/withholding
Relief for foreign taxes
General tax credits
Sample tax calculation
All information contained in this document is summarized by KPMG Limited, the Cyprus member firm affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity, based on the Cyprus Income Tax Law of 2002 (L.118(I)/2002) as amended, the Special Contribution for the Defence of the Republic Law of 2002 (L.117(I)/2002) as amended, the Assessment and Collection of Taxes Law of 1978 (L.4/1978) as amended, the Stamp Duty Law of 1963 (L.19/1963) as amended, the Capital Gains Tax Law of 1980 (L.52/1980) as amended, the Immovable Property Tax Law of 1980 (L.24/1980) as amended, the Cyprus VAT Law of 2000 (N95.(I)/2000) as amended, the Social Insurance Law of 2010 (L.59(I)/2010) as amended and the General Healthcare System Law of 2001 (L.89(I)/2001) as amended.
Following is an overview of the concept of Cyprus’s immigration system for skilled labor.
(E.g. which steps are required, authorities involved, in-country/territory and foreign consular processes, review/draft flow chart illustrating the process)
EU nationals are allowed to undertake employment activities in Cyprus without any restrictions.
Highly skilled third-country/territory national employees may undertake employment in Cyprus either under the normal procedure through the Department of Labour or through the Migration Department if their employer is registered as a Foreign Interest Entity.
1) Employment of highly skilled employees through the Department of Labour
Highly skilled employees with gross annual earnings in excess of 35,000 Euros (EUR) may obtain an approval for employment from the Department of Labour in an expedited procedure. Once the approval from the Department of Labour is obtained the highly skilled employee may proceed with the submission of the work permit application at the Migration Department.
2) Employment of highly skilled employees of a Foreign Interest Entity (FIE)
Highly skilled employees of a FIE, which is registered with the Migration Department may apply directly to the Migration Department for a work permit without the prior approval from the Department of Labour.
Describe (a) which nationalities may enter Cyprus as non-visa national, (b) which activities they may perform and (c) the maximum length of stay.
a) Please refer to the below website for further details regarding countries/territories whose nationals do not need a visa to enter Cyprus for tourism/business purposes
b) Only for business purposes for attending meetings, visits to sites, etc. Actual employment activities are not permitted.
c) Up to 90 days within a 180 days period
Describe (a) the regulatory framework for business traveler being visa nationals (especially the applicable visa type), (b) which activities they may perform under this visa type and the (c) maximum length of stay.
a) Business travelers may enter Cyprus with a tourism visa which will be for business purposes. The relevant application should be submitted to the Cyprus Embassy of the country/territory of residence of the business traveler
b) Business related activities (meetings, visits of sites, etc.). Actual employment activities are not permitted.
c) 90 days within a 180 days period
Outline the process for obtaining the visa type(s) named above and describe (a) the required documents (including any legalization or translation requirements), (b) process steps, (c) processing time and (d) location of application.
Please find below information for the process of obtaining a visa:
Please note that submitting the aforementioned documents does not guarantee automatic issuance of the visa. The Diplomatic Mission (or Consulate) of the Republic of Cyprus, where the visa application is lodged, reserves the right to request additional documents, such as:
Please note that the possession of a valid visa does not grant the holder of an absolute right of entry to the Republic of Cyprus. The applicant may as well be required to present certain evidence upon arrival.
The application submission fees for a short stay visa are EUR20.
The visa should be issues within 15 business days assuming that no further documents are required for the examination of the application.
Are there any visa waiver programs or specific visa categories for technical support staff on short-term assignments?
What are the main work permit categories for long-term assignments to Cyprus? In this context outline whether a local employment contract is required for the specific permit type.
A third-country/territory national should obtain a residence permit for employment purposes from the Migration Department in order to undertake employment activities in Cyprus. For this purpose a local employment contract should be in place.
The main routes for obtaining a work permit are the following:
Provide a general process overview to obtain a work and residence permit for long- term assignments (including processing times and maximum validation of the permit).
As a first step, an approval from the Department of Labour should be obtained for the employment of the third-country/territory national in Cyprus.
Firstly, in order for the company to be eligible to employ third-country/territory nationals it should fulfill the following conditions:
Further, please find below the list of the criteria that should be satisfied, in order for the Department of Labour to recommend the employment of foreign individuals:
Is there a minimum salary requirement to obtain a long term work and residence permit for assignments? Can allowances be taken into account for the salary?
Yes, depending on the type of the application and the position of the individual.
Benefits in kind and bonuses are not included in the required minimum salary.
Is there a fast-track process which could expedite the visa/ work permit?
Yes, if the employer is registered at the Migration Department as a Foreign Interest Entity (FIE)
At what stage is the employee permitted to start working when applying for a long term work and residence permit (assignees/ local hire)?
Once the final application has been submitted to the Migration Department and prior to the issuance of the actual residence permit card.
Can a short term permit/ business visa be transferred to a long term permit in Cyprus?
Yes, depending on the application to be submitted.
Is it possible to renew work and residence permits?
Yes, depending on the type of the application to be submitted.
Is there a quota or system or a labor market test in place?
Yes. For general employment the company should employ a sufficient number of employees from the local labor force to run the business and the number of foreign employees should not be more than 30 percent of the total employees of the company.
For Foreign Interest Entities there is a restriction of employment of up to 5 Directors and 10 middle management staff.
Would it be possible to bring family members to Cyprus?
Yes, through the family reunification process for employees at a foreign interest entity.
Is it possible to obtain a permanent residence permit?
Yes, subject to various conditions.
What if circumstances change after the Work and Residence application process (e.g. change of employment or personal situation, including job title, job role or salary)?
A notification should be submitted to the Migration Department informing them on the relevant changes. Depending on the case, a new application needs to be submitted.
How long can a permit holder leave Cyprus without their permit becoming invalid?
Up to 90 days.
Must immigration permissions be cancelled by the end of the assignment/employment?
No, a notification needs to be submitted to the Authorities
Are there any penalties for individuals and/or companies in place for non-compliance with immigration law?
Yes, strict penalties apply depending on the case.
List any other important items to note, or common obstacles faced, in Cyprus when it comes to the immigration processes.
When are tax returns due? That is, what is the tax return due date?
The deadline for submission of the personal income tax returns is 31 July following the year of income. The tax return is submitted in electronic format via the Taxisnet System.
What is the Tax Year-End?
What are the compliance requirements for tax returns in Cyprus?
Individuals must file their income tax returns electronically via the Taxisnet system, not later than 31 July following the end of the tax year (31 December), in the instance where their gross income exceeds the tax free threshold of 19,500 Euros (EUR).
A claim for deductions and allowances (IR59) is prepared at the beginning of the tax year and a statement of taxable income (IR63) for the tax year must accompany the tax return when submitted.
A self-assessment computation should be completed on the tax return. In the instance where a tax liability arises from the self-assessment computation, the tax should be paid by 31 July following the end of the tax year (e.g. by 31 July 2019 for the 2018 tax year).
After receiving the completed return, the tax office will proceed to issue an assessment of the tax payable and will give credit for the tax deducted from remuneration during the year under the Pay-As-You-Earn (PAYE) system operated by the employer and for any tax paid by the individual through self-assessment. If the tax assessment is correct, any tax due should be paid by the end of the month following the month in which the assessment is raised. If the tax assessment is not correct, a notice of objection must be lodged not later than the end of the month following the month in which the assessment is raised.
Non-tax resident individuals are charged to tax and required to file a return on income accruing or arising from sources within Cyprus i.e. income from employment exercised in Cyprus, if that income exceeds the tax free threshold of EUR19,500.
What are the current income tax rates for residents and non-residents in Cyprus?
Income tax table for 2019
|Taxable income bracket||Cumulative tax||Tax rate on income in bracket|
|From EUR||To EUR||EUR||Percent|
The above tax rates also apply to non–tax residents.
For the purposes of taxation, how is an individual defined as a resident of Cyprus?
Income Tax Law
The Cyprus income tax law defines the term “resident in Cyprus” when applied to an individual, meaning an individual who stays in Cyprus for a period or periods exceeding in aggregate 183 days in the year of assessment (1 January-31 December). A “non-resident or resident outside Cyprus” will be construed accordingly.
Furthermore, the definition of a tax resident has been amended to also provide that, an individual who does not stay in any other country/territory, for one or more periods exceeding in aggregate 183 days in the same tax year and is not tax resident in any other country/territory for the same year, is deemed as a resident in the Republic in that tax year, if all of the following conditions are met:
The law is further amended to clarify that an individual that cumulatively meets all the above conditions shall not be treated as a Cyprus tax resident in the tax year if, during that year the exercise of any kind of business in the Republic and/or employment and/or holding of an office with a tax resident person in the Republic is terminated.
The Special Contribution for Defense (SDC) law, defines the term “resident in Cyprus” when applied to an individual, meaning an individual who is a Cyprus tax resident (as defined in the Income tax law - see paragraph above) and also is domiciled in Cyprus (as defined in the SDC Law). Therefore, if an individual is a Cyprus tax resident for income tax purposes but is not domiciled in Cyprus, s/he will not be considered as a Cyprus tax resident for Special Defense Contribution purposes.
Is there, a de minimus number of days rule when it comes to residency start and end date? For example, a taxpayer can’t come back to the host country/territory for more than 10 days after their assignment is over and they repatriate.
There is no such restriction under Cyprus laws and the Cyprus tax residency is determined solely based on the rules described in the ‘residency rules’ section.
What if the assignee enters the country/territory before their assignment begins?
The days determining residency start as soon as the assignee enters the country/territory. Tax residency is determined solely based on the rules described in the ‘residency rules’ section.
Are there any tax compliance requirements when leaving Cyprus?
Before leaving Cyprus, a tax clearance certificate must be obtained from the Tax Authorities. In order to receive a tax clearance, all tax obligations must be settled.
What if the assignee comes back for a trip after residency has terminated?
The individual is recognized as a Cyprus tax resident, if their stay in Cyprus satisfy the conditions described in the ‘residency rules’ section. Thus, if the assignee comes back for a trip and their overall stay in Cyprus in a calendar year does not exceed 183 days, she/he will not be regarded as a Cyprus tax resident and will only be liable to taxation on income sourced in Cyprus as a non-tax resident, which is in excess of EUR19,500.
Do the immigration authorities in Cyprus provide information to the local taxation authorities regarding when a person enters or leaves Cyprus?
Will an assignee have a filing requirement in the host country/territory after they leave the country/territory and repatriate?
Yes, if she/he spends in Cyprus more than 183 days in a calendar year. Otherwise, only if she/he has income sourced in Cyprus as a non-tax resident, which is in excess of EUR19,500.
Do the taxation authorities in Cyprus adopt the economic employer approach1 to interpreting Article 15 of the Organisation for Economic Co-operation and Development (OECD) treaty? If no, are the taxation authorities in Cyprus considering the adoption of this interpretation of economic employer in the future?
No, the taxation authorities in Cyprus do not adopt the economic employer approach to interpreting Article 15. There are no current plans to adopt it.
Are there a de minimus number of days before the local taxation authorities will apply the economic employer approach? If yes, what is the de minimus number of days?
What categories are subject to income tax in general situations?
The following categories of income are subject to income tax:
Intra-group statutory directors
Will a non-resident of Cyprus who, as part of their employment within a group company, is also appointed as a statutory director (i.e. member of the Board of Directors in a group company situated in Cyprus) trigger a personal tax liability in Cyprus, even though no separate director's fee/remuneration is paid for their duties as a board member?
Yes. The Cyprus tax Authorities will seek to tax in Cyprus a portion of the remuneration of the Individual, which can be attributed to their duties as a member of the board of directors of a Cyprus tax resident company.
a) Will the taxation be triggered irrespective of whether or not the board member is physically present at the board meetings in Cyprus?
Yes. The Cyprus Tax Authorities will seek to tax in Cyprus a portion of the remuneration of the Individual, irrespective of whether the individual will be physically present at the board meetings in Cyprus.
b) Will the answer be different if the cost directly or indirectly is charged to/allocated to the company situated in Cyprus (i.e. as a general management fee where the duties rendered as a board member is included)?
No. The same tax implications will apply.
c) In the case that a tax liability is triggered, how will the taxable income be determined?
The portion of the remuneration that can be attributed to the duties of the individual as a board member of the Cyprus tax resident will be considered as a Cyprus sourced income and will be subject to taxation in Cyprus at the normal income tax rates.
Are there any areas of income that are exempt from taxation in Cyprus? If so, please provide a general definition of these areas.
The categories of income, which are exempt from tax, include:
Reimbursement for relocation expenses is not considered as a benefit in kind and therefore should not be taxable. This exemption is given up to EUR9,000 or the actual costs paid by the employer if there is documentary evidence (i.e. invoices paid).
No tax charge arises in respect of below market rate or interest free loans from an employer.
Medical or health insurance up to 1.5 percent of gross income of an employee is not taxable. Any excess amount is fully taxable.
Are there any concessions made for expatriates in Cyprus?
20 percent or EUR8,550 exemption:
This exemption applies until year 2020 with regard to employment that commenced from 2012 onwards for a maximum period of 5 years.
50 percent exemption
This deduction applies when income exceeds EUR100,000 p.a. and is allowed for a period of 10 years, commencing from the year of employment.
This exemption is not available to individuals that were Cyprus tax residents for a period of 3 out of 5 years preceding the year of employment.
An individual will not be entitled to both exemptions simultaneously.
Is salary earned from working abroad taxed in Cyprus? If so, how?
Tax residents are taxed on their worldwide income.
A foreign tax credit is available up to the level of tax that would have been imposed in Cyprus on the same source of income. Where an expatriate is from a non-treaty country/territory, Cyprus will allow unilateral relief for foreign taxes payable, up to a maximum of the Cyprus tax payable on the same source of income.
The remuneration from rendering outside of Cyprus salaried services for a total aggregate period in the year of assessment of more than 90 days to an employer not resident in Cyprus or to a permanent establishment outside Cyprus of an employer resident in Cyprus is exempt from tax.
Foreign pensions in respect of services rendered outside of Cyprus are tax free in respect of the first EUR3,420 and, thereafter, are taxed at a flat rate of 5 percent. However, the taxpayer may opt to be taxed in the normal way where the special mode of taxing their income results in a higher tax liability.
Are investment income and capital gains taxed in Cyprus? If so, how?
Income from the sale of capital assets, or stocks and shares or options thereon is not taxable.
Capital gains tax is imposed only on any gains (after adjusting for inflation) that arise from the disposal of immovable property situated in Cyprus. These gains are not included in ordinary income but are taxed separately at a flat rate of 20 percent. Gains from immovable property held outside of Cyprus are not liable to capital gains tax.
A full exemption from Capital Gains Tax is granted on any capital gains derived from the sale of immovable property, which was acquired from 16/07/2015 until 31/12/2016.
Capital losses cannot be set-off against taxable income.
Capital losses arising from the disposal of immovable property situated in Cyprus are set off against chargeable gains made on the same date. If there are no gains on the same date or if the gains are not enough to absorb the capital losses, any unrelieved loss is carried forward and is set off against a chargeable gain or gains made from a future disposal until the loss is relieved.
No loss, however, may be allowed to be carried back and set off against a gain of a previous disposal.
Losses arising from the disposal of exempt assets (i.e. securities) are not allowable.
Lifetime exemptions are available to individuals for capital gains up to EUR17,086 or in the case of agricultural land owned by a farmer, up to EUR25,629. Gains on the disposal of a dwelling house are exempt up to EUR85,430 if the owner resides in it continuously for at least 5 years before the disposal. These exemptions are not available separately. Therefore, an individual claiming a combination of these, is only entitled to a maximum exemption of EUR85,430.
Dividends and interest are exempt from income tax but are subject to the Special Defence Contribution tax at a rate of 17 percent and 30 percent respectively. SDC is levied only on Cyprus Tax Resident individuals who are also Cyprus Domiciled.
In case of Cyprus sourced dividends and interest, the tax is withheld at source. Special Defence Contribution tax on foreign sourced dividends and interest must be paid on a self-assessment basis by the individual taxpayer by the end of the 6 months ending 30/6 and 31/12 of each year at the latest.
Rental income received by a Cyprus resident is taxable under both the income tax and the Special Defence Contribution tax as follows.
The net taxable rental income (after deducting 20 percent from gross rental income, any available capital allowances and interest on loan for the acquisition of the property) is included in the taxable income and taxed at the appropriate income tax rate.
Under the Special Defence Contribution tax, an amount of 25 percent is deducted from the gross amount of rental income. After this deduction, the remaining amount of rental income is subject to Special Defence Contribution tax at a rate of 3 percent.
It should be noted that as from 16/07/2015 an amendment to the Special Contribution for Defence (SCD) law has been enforced. Based on the new provisions of the SDC law any dividends, interest and rents received by individuals who are Cyprus tax residents but are not domiciled in Cyprus (as defined in the SCD Law), irrespective of the origin of the relevant income (i.e. from sources within Cyprus or abroad), are exempt from taxation.
|Residency status||Taxable at:|
|Other (if applicable)||N/A||N/A||N/A|
* Only on difference between sale price less cost to acquire.
Gains realized from the disposal of personal use items (such as works of art, jewelry, coins, stamps, antiques etc.) are not subject to Cyprus personal income tax. Consequently, any losses incurred from such a disposal are not tax deductible.
Gifts are not taxable.
Are there additional capital gains tax (CGT) issues in Cyprus? If so, please discuss?
No additional issues other than those covered above.
Are there capital gains tax exceptions in cyprus? If so, please discuss?
No additional issues other than those covered above.
What are the general deductions from income allowed in Cyprus?
Generally all outgoings and expenses wholly and exclusively incurred in the production of income are deductible for tax purposes. Specifically, however, the following deductions are allowed:
What are the tax reimbursement methods generally used by employers in Cyprus?
Current year gross-up is the normal method used.
How are estimates/prepayments/withholding of tax handled in Cyprus? For example, Pay-As-You-Earn (PAYE), Pay-As-You-Go (PAYG), etc.
Tax on employment income must be withheld by the employer, under the PAYE system and remitted to the Tax Authorities monthly. This tax is credited towards the employee’s final tax liability. The employer has the obligation to submit annually tax form (IR7) entitled “Employer’s Return of Employees”. This return should be filed by the employer not later than 31 July of the year following the year of assessment, via the Taxisnet system.
Is there any Relief for Foreign Taxes in Cyprus? For example, a foreign tax credit (FTC) system, double taxation treaties, etc.?
Yes, relief for foreign taxes suffered is available through a network of Double Tax Treaties up to the level of tax that would have been imposed in Cyprus.
Where an expatriate is from a non-treaty country/territory, Cyprus will allow unilateral relief for foreign taxes payable, up to a maximum of the Cyprus tax payable on the same source of income.
What are the general tax credits that may be claimed in your country/territory? Please list below.
When the final tax liability is computed, credit is given for taxes withheld at source and for interim tax payments.
This calculation assumes a married taxpayer coming to Cyprus with two children whose 3-year assignment begins 1 January 2017 and ends 31 December 2019. The taxpayer is entitled to an annual base salary of USD100,000, an annual bonus, cash allowances and various benefits in kind which are listed below. The calculation covers 3 years.
|Moving expense reimbursement||20,000||0||20,000|
|Interest income from non-local sources||6,000||6,000||6,000|
Exchange rate used for calculation: EUR1= USD1.1993 (31/12/2017)
Calculation of taxable income
|Days in Cyprus during year||345||330||320|
|Earned income subject to income tax:|
|Moving expense reimbursement||16,676||0||16,676|
|Total earned income||145,084||132,577||145,084|
|Total income subject to income tax||145,084||132,577||145,084|
|50 percent Exemption**||72,542||66,289||72,542|
|Social Insurance contributions***||4,243||4,243||4,536|
|National Health Insurance Contributions****||2,055|
|Total taxable income||68,299
Calculation of tax liability
|Taxable income as above||68,299||62,045||65,951|
|Cyprus tax thereon||13,790||11,601||12,968|
|Tax rebates (dependent spouse)||0||0||0|
|Foreign tax credits||0||0||0|
|Total Cyprus tax||13,790||11,601||12,968|
* Interest income is exempt from income tax but the gross amount is subject to Special Defence Contribution at a rate of 30 percent with tax credit available for any foreign withholding tax suffered. Based on the new provisions of the SDC law any interest income received by individuals who are Cyprus tax residents but are not domiciled in Cyprus irrespective of the origin of the relevant income (i.e. from sources within Cyprus or abroad) are exempt from taxation.
** 50 percent of the gross emoluments are allowed to be deducted from taxable income for individuals that were not a tax resident of Cyprus prior to the commencement of their employment in Cyprus.
This deduction applies when income exceeds EUR100,000 p.a. and is allowed for a period of 10 years, commencing from the date of employment.
**** Social insurance contributions assuming that the expatriate is subject to Social Insurance in Cyprus:
For 2017-2018 year: Maximum yearly insurable earnings EUR54,396*7.8 percent
For 2019 year: Maximum yearly insurable earnings EUR54,648 x 8.3 percent
**** (1.7 percent*10/12*Total income subject to tax), since National Health Insurance contributions has come into effect as of 1 March 2019.
1 Certain tax authorities adopt an “economic employer” approach to interpreting Article of the OECD model treaty which deals with the Dependent Services Article. In summary, this means that if an employee is assigned to work for an entity in the host country/territory for a period of less than 183 days in the fiscal year (or a calendar year of a 12-month period), the employee remains employed by the home country/territory employer but the employee’s salary and costs are recharged to the host entity, then the host country/territory tax authority will treat the host entity as being the “economic employer” and therefore the employer for the purposes of interpreting Article 15. In case, article 15 relief would be denied and the employee would be subject to tax in the host country/territory.
2 For example, an employee can be physically present in the country/territory for up to 60 days before the tax authorities will apply the economic employer approach.
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