The new taxation status on Company is residence-based. A company is only ‘resident in the Republic’ if its business in centrally managed and controlled in Cyprus. Therefore, under the new rules, a resident corporation is taxable on its worldwide income accrued or arising from sources both within and outside Cyprus if it is managed and controlled from Cyprus.
‘Management & Control’ means that:
(a) all strategic (and preferably also day-to-day) management decisions are taken in Cyprus by the directors exercising their duties from Cyprus. This is usually achieved by having meetings of the Board of Directors take place in Cyprus and signing written resolutions, contracts, agreements and other relevant company documents relating to the management, control and administrative functions of the company in Cyprus;
(b) the majority of the directors of the company are tax resident in Cyprus and exercise their office from Cyprus;
(c) an actual (administrative) office is maintained in Cyprus, where the actual management and control of the business of the company shall be exercised;
(d) hard copies of commercial documentation (agreements, invoices, etc) are stored in the office facilities of the company;
(e ) accounting records of the company are prepared and kept in Cyprus;
(f) bank accounts of the a company are operated from Cyprus, even if the accounts are maintained with banks established outside Cyprus.