Private Wealth 2026 Comparisons

The main taxes applicable in Cyprus for individual clients, estates, trusts and foundations are as follows.

• Income tax – levied at rates ranging between 0% and 35%, depending on the taxpayer’s level of income.
• Capital Gains Tax (CGT) – charged at 20% and only applies to profit from the sale of immovable property in Cyprus including, upon the satisfaction of certain conditions, the sale of shares of a company that directly or indirectly owns immovable property situated in Cyprus. The sale of shares in companies that are listed on a regulated market of a recognised stock exchange is exempt from CGT.
• Corporation Tax – levied at the rate of 15%.
• Special Contribution for Defence (SDC) – imposed on dividends at the rate of 5% and interest at the rate of 3% (on interest earned on listed corporate bonds, Cypriot or other EU member states bonds, etc) or 17% (on other interest). The SCD applies to individuals who are both Cyprus tax residents and Cyprus-domiciled. 
• Inheritance, estate or gift tax – Cyprus does not currently impose any of these taxes.
• Cyprus social insurance and General Healthcare System (GHS) contributions apply to individuals, employees, directors and self-employed persons. Employees and employers contribute to social insurance, with the standard employee and employer social insurance rate being 8.8%, while self-employed persons generally contribute 16.6% on insurable earnings. Separately, GHS contributions apply to employment, self-employment, pensions and passive income, such as dividends, interest and rents, with the GHS annual contribution base capped at EUR180,000 per individual.
• Cyprus is a party to more than 65 tax treaties that provide for nil or reduced withholding tax rates on dividends, interest, royalties and pensions received from abroad. Withholding taxes are imposed on payments of dividends to low tax and/or non-cooperative with EU jurisdictions (subject to conditions).
• When a Cyprus tax resident payer receives income from outside of Cyprus, which is subject to tax in Cyprus and has also been taxed abroad, they are entitled to a tax credit for the foreign taxes paid on that income in the foreign countries in which the income was generated, irrespective of whether a double tax treaty exists. The amount of tax credit cannot exceed the Cyprus tax arising on the specific income.

The following tax exemptions exist in Cyprus.

Estate Duty, Wealth Tax, Gift Tax and Inheritance Tax

There is no estate duty, wealth tax, gift tax or inheritance tax in Cyprus.

Exemptions Under the Non-Domiciled Status Applicable for Individuals

A Cyprus non-domiciled tax resident individual is exempt from tax on dividend and interest income.

However, for Cyprus tax resident individuals (irrespective of their domicile status), such income is subject to contributions to the GHS at the rate of 2.65%.

No Tax on Gains Arising From the Disposal of Investments

Any gains arising from the disposal of shares (except where certain conditions are met as per 1.1 Tax Regimes), bonds and other similar financial instruments (including options and rights thereon) are exempt from tax.

However, such income (of trading nature only) is subject to contributions to the GHS at the rate of 2.65%.

No Tax on Retirement Gratuity and Special Tax Regime on Foreign Pension Income

Any lump sum received as a retirement gratuity is exempt from tax. Further, a Cypriot tax resident individual receiving pension income from services rendered abroad may choose to be taxed at a flat rate of 5% on amounts exceeding EUR5,000 per annum.

Exemption From CGT on Sale of Real Estate

Gains arising from the disposal of non-Cypriot real estate are exempt from CGT. Lifetime exemptions are available on disposals of real estate situated in Cyprus.

Favourable Tax Regime on Crypto-Assets

Gains arising from the sale of a crypto-asset, the gift of a crypto-asset, the exchange of a crypto-asset with another crypto-asset and the use of a crypto-asset as means for making payments are subject to income tax at a flat rate of 8%.

This special mode of taxation does not apply for gains on crypto-assets that were acquired through mining.

Income Tax Exemptions for Taking Up Employment in Cyprus

An expatriate individual relocating to Cyprus (irrespective of their tax residency or domicile status) is eligible to one of the following income tax exemptions on employment income.

• A 50% exemption from the remuneration from the employee's first employment in Cyprus available to employees who were not residents of Cyprus for a period of at least 15 consecutive years immediately before the commencement of their employment in Cyprus.

The exemption applies for a period of 17 years, starting from the first year of employment in Cyprus, provided that their remuneration exceeds EUR55,000.

• A 20% exemption from the remuneration from the employee's first employment in Cyprus available to employees (up to a maximum exemption of EUR8,550 per annum), provided that the employees, immediately before the commencement of their employment in Cyprus, were employed outside of Cyprus by a non-Cyprus resident employer for at least three consecutive tax years.

The exemption applies for a period of seven years, and is first granted in the tax year following the tax year in which the employment commenced in Cyprus.

• Income Tax Exemption for Overseas Employment

The rendering of salaried services outside Cyprus to a non-Cyprus tax resident employer, or to an overseas permanent establishment of a Cyprus tax resident employer, for more than 90 days in a tax year, is exempt from income tax.

Share-Based Payments to Employees

Benefits derived from employees and/or directors of a company in the form of share option rights or rights for acquisition of shares are subject to a flat tax rate of 8% (subject to conditions).

Variable Remuneration of Individuals Employed in the Funds Industry (Subject to Conditions)

The variable remuneration of employees of (i) an Alternative Investment Fund (AIF) Manager or self-managed AIF; or (ii) a Management Company for Collective Investments in Transferable Securities (UCITS), which is connected to the carried interest, is taxed at a flat rate of 8% with a minimum tax liability of EUR10,000 per annum (subject to conditions). Qualifying employees can elect to be taxed under this special mode of taxation on an annual basis for a ten-year period or otherwise be taxed in accordance with the personal income tax rates.

Cyprus, combined with its high quality of life, strategic location, modern infrastructure, and business-friendly environment, is considered one of the most attractive destinations for international professionals and investors seeking both tax efficiency and substance within an EU jurisdiction. It offers useful income tax planning opportunities, mainly through the tax exemptions and other benefits that are provided in the Cyprus Tax Laws (see 1.2 Exemptions).

More specifically, the Cyprus Non-Domicile (“Non-Dom”) regime is one of the most attractive personal tax incentives available within the EU, designed to attract international entrepreneurs, executives, investors, and high net worth individuals to Cyprus.

Individuals who become Cyprus tax residents but are not considered domiciled in Cyprus for tax purposes may benefit from significant exemptions on passive income for a period of up to 17 years. In particular, non-dom individuals are exempt from the SDC tax on dividend and -interest income.

As a result, qualifying individuals can receive dividends and certain investment income (eg, interest and gains on sale of listed shares) free from Cyprus taxation, making Cyprus a highly efficient jurisdiction for international wealth structuring and investment holding activities. Additionally, individuals may also be benefited from the special tax regimes that are available for pensioners, employees and traders in crypto-assets.   

The Cyprus Non-Dom framework is fully aligned with international transparency and compliance standards while continuing to provide substantial benefits to foreign individuals relocating to Cyprus.

Any tax planning must be genuine, documented and commercially or family-planning driven, rather than artificial or purely tax-motivated.

For individuals moving to Cyprus, the key pre-immigration planning is to decipher whether they will become a Cyprus tax resident under the 183-day rule or the 60-day rule, or whether they can qualify as non-dom for SDC purposes. Cyprus tax residents are generally taxed on worldwide income, but non-dom individuals remain exempt from SDC on dividends and interest, while non-residents are taxed only on Cyprus-source income.

On exit, Cyprus does not generally impose a personal exit tax on individuals merely because they cease their Cyprus tax residence. The main planning point is to ensure the individual ceases to be a Cyprus tax residence under the day-count rules and to identify any continuing Cyprus-source income, Cyprus real estate, Cyprus companies or trusts with Cyprus-resident beneficiaries. Cyprus exit tax rules are mainly applicable to corporate taxpayers moving assets or tax residence outside the Cyprus tax net, not ordinary individual departure planning.

In Cyprus, real estate owned by non-residents and non-citizens is taxed as follows.

• CGT: non-residents pay CGT only on gains from Cyprus-based immovable property or related shares as further explained in 1.1 Tax Regimes. Where a company derives its value primarily from immovable property situated in Cyprus, CGT may be triggered, even if the transfer is executed through offshore share transactions.
• Income Tax and GHS Contributions: non-residents in Cyprus are taxed on rental income from Cyprus property through income tax and GHS Contributions (subject to ceiling amount of income of EUR180,000, per individual, per year). Rental income may also be subject to VAT in certain commercial leasing cases.

Cyprus has a very stable tax system, which was largely the same for the last 15 years, until a recent tax reform which took effect on 1 January 2026.

There are no other current plans or proposals to change the tax regime in Cyprus.

Cyprus is fully compliant with the EU directives relating to tax and exchange of information matters and has addressed possible abuse or loopholes in tax laws in the following ways.

• Anti-abuse actions: GAAR (Income Tax Law for artificial arrangements)/transfer pricing rules (needs documentation)/substance requirements (for companies and holding structures). Anti-abuse actions preserve the stability of the private-client regime.
• CRS (Common Reporting Standard): Cyprus applies CRS, requiring automatic reporting of offshore accounts and trusts, ensuring full financial transparency.
• FATCA:
1. All main banks collect tax residency and TIN details from all clients.
2. Account data is reported annually to tax authorities for international exchange.
3. Offshore accounts, companies, and trusts are fully transparent.
4. Incorrect or missing info may trigger compliance checks.
5. Banking secrecy is no longer available for tax purposes.
• EU DAC 6 – Mandatory Disclosure Rules: Cyprus applies EU DAC 6 rules and maintains a beneficial ownership register to prevent tax abuse and improve transparency. Information is shared with authorities but not fully public, balancing compliance with privacy.

In Cyprus, succession planning is strongly influenced by close knit families and there is a preference for keeping wealth, land and family businesses within the family alongside a desire to treat children fairly. Older generations may be hesitant to transfer full control during their lifetime, especially over real estate or family businesses, so planning often focuses on continued control and an orderly transfer of wealth. In light of this, as generations pass, the families grow larger and there is a recurring theme of either new generations not wanting to take over the family business or disputes between family members.

Accordingly, older generations are seeking tax efficient ways to turn over wealth to the younger generations, and where possible, sell the business so that younger generations can make a fresh start.

Separately, Cyprus forced heirship rules are also important, as they can restrict full testamentary freedom and make early planning necessary for desired outcomes (as further outlined in 2.3 Forced Heirship Laws).

Cyprus residents, locals and high net worth individuals (HNW) relocating to Cyprus often have:

• heirs living in different jurisdictions;
• assets abroad/outside of Cyprus;
• mixed tax residencies within the same family; and
• exposure to forced heirship rules, foreign estate taxes and/or issues and concerns arising from double taxation treaties.

This may create cross-border conflicts between Cyprus laws and practice, foreign inheritance rules and foreign tax regimes. All of these need to be taken into account when succession planning is undertaken, to ensure that such clients/individuals achieve adequate planning in the most efficient and appropriate way.

Cyprus applies forced heirship rules under the Wills and Succession Law, where the deceased was domiciled in Cyprus, at the time of death.

These rules outline a fixed statutory portion of the estate to pass to close family members, such as a spouse, children or, in certain cases, parents (depending on who the surviving close family members are), while only the remaining disposable portion may be freely distributed by will. In practice, this means that individuals cannot freely elect to whom their estate will pass upon death. Accordingly, if they have specific wishes, they will need to take appropriate action during their lifetime. Generally speaking, lifetime gifts, trusts and other holding structures may also be considered as mechanisms for managing succession outcomes. Additionally, Cyprus, as a member of the EU, is bound by the European Succession Regulation (EU) No 650/2012 (commonly called the Brussels IV Regulation), which offers certain mechanisms (like Choice of Law under Article 22 and Agreements as to Succession under Article 25) that may be employed in order to circumvent forced heirship restrictions in certain circumstances, subject to proper estate planning.

In cross-border cases, however, there may be greater flexibility. Non-Cyprus-domiciled individuals may be able to rely on the law of their nationality or another applicable foreign law, particularly where the EU Succession Regulation (Brussels IV) is relevant. This, ultimately, depends on the exact circumstances so it is considered and assessed on a case-by-case basis.

In Cyprus, unlike some other jurisdictions, marriage does not automatically alter the property rights of the spouses and does not automatically create a community of property or joint-property regime. As a starting point, property acquired before the marriage or before cohabitation with the intention of marriage cannot be the subject matter of an asset division dispute between spouses. As a general rule, each spouse generally retains ownership and control of property held in their own name, including property acquired before or during the marriage.

The Cypriot matrimonial property regime is based on the principle of separate property ownership. Nevertheless, where a marriage is dissolved, or the spouses separate, the division of assets will be generally resolved by establishing whether one of the spouses has made a greater contribution to the increase of the property acquired during the marriage. Therefore, a spouse who has contributed to the increase in the property of the other spouse is entitled to claim a share of that increase corresponding to their contribution. The law establishes a rebuttable presumption that such contribution is equal to one-third of the increase, unless the evidence demonstrates a greater or lesser contribution.

Given that Cyprus is not a community-property jurisdiction, each spouse can generally deal with property registered in their own name. However, in the case of separation or where one spouse seeks to dispose of or deal with an asset in order to defeat or hinder the execution of a property claim by the other spouse, the court may intervene, usually through the issuance of an appropriate order to protect the asset(s) until the case is tried.

Moreover, upon separation, or upon the institution of divorce proceedings, the Family Court may, on the application of either spouse, grant one spouse the exclusive right to occupy the family home, irrespective of which spouse actually owns the property or otherwise holds the legal right to occupy it. In exercising this discretion, the Court must consider the requirements of equity, the particular circumstances of each spouse, and the best interests of any children.

Prenuptial agreements are generally treated as non-binding in Cyprus, although post-separation agreements settling property issues may be enforceable as ordinary contracts if they meet the usual requirements of valid consent, certainty and absence of fraud, duress or illegality.

As mentioned in 1.2 Exemptions, Cyprus has no inheritance, estate or gift tax, therefore transfers between relatives up to the third decree do not usually trigger a tax event and generally do not reset the cost basis.

Transfers between non-relatives may be subject to tax depending on the nature of the asset to be transferred, taking into account the market value of the asset rather than cost of the property.

In Cyprus, transfer fees on immovable property are payable to the Department of Lands and Surveys and are generally calculated on the sale price or the market value of the property, as determined by the Director of the Department of Lands and Surveys, where applicable.

In the case of a gift, transfers between parents and children are exempt from transfer fees when calculated on 1 January 2013 values. Gifts between spouses and between relatives up to the third degree of kinship (other than parent-to-child transfers) are subject to nominal transfer fees based on 1 January 2013 values. In certain cases involving property located in the occupied areas of Cyprus, registration may be completed without fees until a political settlement.

The 1 January 2013 values refer to the general valuation carried out by the Department of Lands and Surveys as at 1 January 2013, which is used for statutory and tax purposes, is not representative of market value, and is available online through the official Department of Lands and Surveys portal.

In the case of a sale, transfer fees are generally calculated on a progressive scale (3% up to EUR85,000, 5% from EUR85,001 to EUR170,000, and 8% above EUR170,000), based on the sale price or market value, whichever is higher, subject to a 50% reduction in most cases. No transfer fees are payable where VAT is charged on the same transaction. The Director of the Department of Lands and Surveys may reassess the declared value if it is not considered to reflect market value.

As described in 2.5 Transfer of Property, the transfer of assets between relatives up to the third degree is generally not subject to tax. Furthermore, Cyprus does not impose inheritance, estate, or gift tax. Therefore, there may be no need for specific planning in transferring assets owned by individuals to younger generations.

However, if the assets are held under a Cyprus tax resident company, tax planning may be required for transferring the assets to the younger generations tax free.

Cyprus Income Tax Law includes provisions for tax free re-organisations (eg, mergers, de-mergers, partial divisions, exchange of assets) through which the assets could be transferred to younger generations tax free.

Having said this, tax planning is highly recommended before setting up any structure, taking into account that the main planning tool include lifetime gifts (including tax-free transfers of immovable property between close relatives), the creation of a Cyprus International Trust (CIT) or local trusts (as may be applicable on a case-by-case basis), and family holding companies, which allow parents to transfer shares gradually in a tax-efficient manner.

Cyprus succession law does not have a separate statutory regime for digital assets. Instead, digital assets, such as cryptocurrency, tokenised assets, online accounts, cloud-stored data and email accounts, are treated as part of the deceased’s movable estate under the Wills and Succession Law and the Administration of Estates Law. As a result, although this is not well tested or established, such assets may pass under a Cyprus will, under statutory succession, or under a foreign law chosen pursuant to Brussels IV.

In practice, the main issues relate to access and control, not legal entitlement. Service providers (email platforms, cloud services, social-media companies, exchanges) apply strict privacy and security policies and typically require probate documents, and in some cases a court order, before releasing account access or data. For cryptocurrency, heirs can only administer the asset if they have the private keys, seed phrases or wallet credentials; without these, the asset cannot be recovered.

As with most jurisdictions, this is a relatively new area of law and has not yet been sufficiently tested in the courts.

Generally speaking, there are a number of main vehicles for tax-efficient wealth structuring in Cyprus, such as the CIT, foundations, family investment companies (FIC) and companies limited by guarantee. These options are summarised below.

CITs

• Use: estate planning during lifetime, asset protection, possibility of avoiding the forced heirship rules.
• Advantages: high flexibility, confidentiality, creditor protection, tax-neutral for non-resident settlors/beneficiaries.
• Limitations: settlor and beneficiaries must not be Cyprus tax residents in the year before creation.

Cyprus Foundations

• Use: civil law alternative to trusts. Suitable for family governance, or commercial holding structures.
• Advantages: long-term continuity. They can operate like family foundation with council/guardian oversight. 
• Limitations: heavier compliance, auditing and Registrar supervision. They are generally more complex to set up and not as tried and tested as other vehicles.

FICs

• Use: passing control and economic rights to younger generations through share classes, holding family assets.
• Advantages: corporate governance, control retention, succession planning without forced heirship.
• Limitations: the corporate tax rate has increased to 15%, while exemptions for dividend income and gains from securities remain important for holding company planning.

Such FICs may be either private companies limited by shares, or, in certain instances, private companies limited by guarantee are even more efficient and beneficial in such succession planning scenarios.

Cyprus fully recognises and strongly protects trusts. Both local trusts and CITs operate under a clear common law framework and are upheld by the courts, provided that they are validly set up, there are no issues as to whether they are a sham, etc. 

While both types of trust are very beneficial and well used, CITs offer better asset protection, the ability to potentially avoid the forced heirship rules, strict confidentiality and wide flexibility, including long duration and reserved settlor powers. However, as mentioned in 3.1 Types of Trusts, Foundations or Similar Entities, in order to be able to set up a CIT, the settlor and beneficiaries must not be Cyprus tax residents in the year before the CIT was established. 

Trusts are treated as transparent entities for tax purposes in Cyprus and, therefore, the method of taxation of income received by the trusts depends on the tax residency of the beneficiaries.

Cyprus-source income is taxed normally, but foreign-source income for non-resident beneficiaries is generally exempt, and all trusts remain private while meeting AML and beneficial-ownership requirements (eg, exchange of information under FATCA/CRS).

Cyprus taxes individuals involved with foreign trusts or foundations strictly based on their tax residency and domicile. A Cyprus–resident fiduciary is taxed only on fees or remuneration earned for acting as trustee or council member, and the trust’s foreign income is not attributed to them personally. For beneficiaries, non-residents are taxed only on Cyprus-source income, while Cyprus tax residents are taxed on worldwide income but may use the non-dom regime to achieve exemptions, including a full exemption from the SDC on foreign-source dividend and interest income. Capital distributions are generally not taxable. These rules create strong planning opportunities, allowing foreign trusts to accumulate income offshore and distribute it tax-free to Cyprus non-dom beneficiaries, thereby, enabling families to combine foreign structures with Cyprus residency for efficient long-term wealth and succession planning.

In Cyprus, the tax result does not depend simply on whether a person is called a fiduciary, donor/settlor or beneficiary; it depends mainly on tax residence, domicile, source of income, and the level of control retained or exercised.

If a Cyprus tax resident beneficiary is also a trustee, protector or other fiduciary, Cyprus may tax that person on trust income or gains allocated or distributed to them, particularly where the income is Cyprus-source or where the beneficiary is a Cyprus tax resident. For CITs, the general rule is that Cyprus-resident beneficiaries are taxed on worldwide trust income and gains, while non-resident beneficiaries are generally taxed only on Cyprus-source income. A Cyprus resident fiduciary is taxed only on trustee frees, while distributions are taxed according to the beneficiary’s residency and domicile, with non-dom receiving foreign source dividends and interest tax-free. In practice, these risks are managed by appointing independent professional trustees, using protectors or reserved powers instead of settlor as trustee arrangements, and maintaining clear documentation to preserve the trust’s validity and tax advantages.

In Cyprus, a donor or beneficiary who also serves as a fiduciary is not subject to automatic adverse tax consequences, but excessive control can risk the structure being treated as a sham or as a domestic trust, leading to taxation on worldwide income.

A beneficiary or donor acting as the fiduciary of the trust is responsible for the tax administration (assessing the tax liabilities, making the payments on behalf of the beneficiaries, filing the tax returns, etc).

The most commonly used asset protection structure in Cyprus is a trust and, in particular, where applicable, the CIT. Trusts are widely used to shield family wealth, separate personal assets from business or creditor risk and facilitate long-term succession planning. They remain popular because assets transferred into the trust cannot be challenged by creditors unless certain criteria are met, for example, the transfer was made with proven intent to defraud.

The main limitations are that a CIT must satisfy the statutory conditions and will not protect assets from pre-existing creditor claims, fraudulent transfers, sham arrangements, improper administration, or structures where the settlor retains excessive control. Trustees are subject to AML/KYC obligations and must register the trust in the Cyprus Trusts Register, which reduces confidentiality even though the register is not public. Cyprus-source assets, especially Cyprus immovable property, may still be exposed to Cyprus tax and legal rules. In practice, asset protection planning requires independent professional trustees, clear trust documentation, proper governance, record-keeping, genuine administration in Cyprus, and compliance with beneficial ownership, AML and reporting obligations.

Please refer to 3.1 Types of Trusts, Foundations or Similar Entities.

The market value depends on whether such transfer is treated as disposal or as a gift between relatives up to the third degree.

If the transfer is made as a gift/inheritance to a relative up to the third degree of kinship, the cost of the transferor is taken into account. In other cases, the market value is taken into account.

Wealth disputes in Cyprus are becoming more frequent and more sophisticated, reflecting both regulatory developments and changes in the way private wealth is held and transferred. Increased transparency obligations arising from EU anti-money laundering (AML) legislation, the CRS, sanctions and asset-freezing measures, and beneficial ownership disclosure requirements have resulted in greater scrutiny of wealth structures and, in some cases, have fuelled disputes concerning the administration of assets, access to information and the rights of beneficiaries.

Another notable development is the ongoing transfer of wealth between generations. As ownership and control of family businesses, real estate and other significant assets pass from one generation to the next, disagreements often arise over succession planning, governance, expectations of inheritance and the distribution of family wealth. These issues are particularly acute where lifetime arrangements are informal or where different family members have played varying roles in the preservation or growth of the family’s assets.

Estate and succession disputes commonly involve challenges under Cyprus’ forced heirship regime, as well as claims concerning the validity of wills, lifetime gifts and other succession arrangements. Allegations of fraud, forgery, undue influence, lack of capacity, broken promises, proprietary estoppel and unequal treatment between heirs are also regularly encountered, particularly in high-value family estates.

Trust disputes typically centre on the conduct of trustees and the administration of trusts. Common claims include breach of fiduciary duty, disputes over the validity of trust structures, allegations of fraud or dishonest assistance, challenges brought by creditors or spouses seeking to reach trust assets, and claims that assets were transferred to defeat creditors, including under the Fraudulent Transfers Avoidance Law within the applicable two-year limitation period.

Given the international profile of many Cyprus-based wealth structures, disputes increasingly have a cross-border dimension. It is now common for proceedings to involve assets, beneficiaries or fiduciaries located in multiple jurisdictions, giving rise to issues concerning beneficial ownership, control of family companies, the recognition of foreign judgments, and the co-ordination of parallel proceedings.

As a common law jurisdiction, the overarching rationale for damages in claims of this nature is compensatory and restitutionary rather than punitive: the court aims to make good any loss and, where appropriate, to deprive the wrongdoer of any profit derived from the breach. While punitive or exemplary damages are not a typical feature of trust or fiduciary litigation in Cyprus, the courts retain a general discretion to award such damages in exceptional cases. The applicable rules concerning remedies awarded under Cyprus law are derived from statute, such as the Trustees Law (Cap. 193) and the International Trusts Law (Law 69(I)/1992), as well as principles of equity.

Such remedies may include:

• equitable compensation (ie, monetary relief to restore the claimants to the position they would have been in but for the wrongdoing or breach);
• an account of profits (compelling a defaulting trustee or dishonest third party to disgorge gains derived from the breach);
• rescission of transactions; and
• proprietary remedies, such as following trust property into the hands of third parties who are not bona fide purchasers for value without notice, and tracing its converted value into substitute assets.

Where equity identifies that a person holds property unconscionably, the courts may also impose a constructive trust for the benefit of the aggrieved party.

In addition, Cyprus courts have a wide jurisdiction to grant interim relief under appropriate circumstances, including injunctions to restrain a breach of trust and the appointment of receivers over trust property.

In the past few years, the use of corporate and professional fiduciaries in Cyprus has been increasing, and such fiduciaries, including Administrative Service Providers (ASPs) play a central role in the country’s international business and wealth management sectors.

Such fiduciaries and ASPs are subject to a higher standard of conduct than private individuals who may act as trustees. While non-professionals are judged by an ordinary prudency-test, licensed fiduciaries must exercise enhanced skill, care, and diligence, which is expected of experts. Additionally, they are regulated under relevant local and European fiduciary services legislation and are supervised by the Cyprus Securities and Exchange Commission (CySEC), the Cyprus Bar Association (CBA) or the Institute of Certified Public Accountants of Cyprus (ICPAC) (as may be applicable).

While trust deeds or other commercial arrangements with such professionals usually include an indemnity, indemnifying the trustee from any personal liability, provided that they act in good faith and do not exceed their authority, this cannot exclude any liability arising from (gross) negligence or fraud.

While ordinarily trust agreements would include (i) provisions giving powers to the trustees to appoint third-party professionals; and (ii) indemnities protecting the trustees from any liabilities, as mentioned in 6.1 Prevalence of Corporate Fiduciaries, trustees cannot exclude any liability which may arise from their negligence or fraud.

Additional, relevant laws would provide, to a certain extent, protection but such protection would not extend to cases involving dishonesty or gross negligence.

In Cyprus fiduciary’s investment is regulated through a combination of English equitable principles, the Trustee Law, and the International Trusts Law, as may be applicable. Relevant laws provide wide investment powers to trustees, which are largely similar to the powers that the settlor would have had prior to the creation of a trust. Additionally, the trustee(s) obligations require good faith, prohibit any conflict of interest, and trustee(s) need to act in the best interests of the beneficiaries given that they are fiduciary in nature.

Having said this, recently, trust deeds have explicitly outlined the trustee’s powers, which may expand or restrict the powers granted by statute. While trustees may use their powers quite broadly, they must act with the care and judgement of a prudent person managing their own assets. Professional fiduciaries are held to an even higher standard.

It is useful to note that professional fiduciaries are licensed and monitored under CySEC, CBA or ICPAC, as applicable on a case-by-case basis.

Generally speaking, trustees need to be prudent in their choice of investments, which is a principle enshrined in the Trustees Law. This empowers trustees to invest globally in movable or immovable assets as if they were the absolute owners.

The “prudent” person standard means that the trustees invest the trust property in a similar way as a reasonable person would do when managing/investing their own affairs and assets. It is not unusual for this standard to be interpreted more strictly due to the trustees’ fiduciary obligations.

It is seen through case law that trustees have to prioritise the beneficiaries’ interests over their own personal or ethical beliefs.

Domicile

Cyprus follows the common law concept of domicile of origin and domicile of choice. A person acquires a domicile of origin at birth and may acquire a domicile of choice by permanently settling in Cyprus with the intention to reside indefinitely. For tax purposes, Cyprus also applies the non-dom test, where an individual becomes Cyprus- domiciled for SDC purposes after 17 years of Cyprus tax residency.

Residency

Residency in Cyprus can either be tax residence or immigration residence, as set out below.

For individuals, Cyprus tax residency is generally determined by either the 183-day rule or the 60-day rule. Under the 183-day rule, an individual is tax resident if they spend more than 183 days in Cyprus during the calendar year. Under the 60-day rule, applicable in 2026, an individual may also be tax resident if they spend at least 60 days in Cyprus, do not spend more than 183 days in any other single country, maintain a Cyprus employment, business or directorship link, and have a permanent home in Cyprus, whether owned or rented.

Immigration residence is separate from tax residency. EU/EEA citizens and their family members must apply for a Cyprus Registration Certificate if staying for more than three months, while non-EU nationals require the appropriate residence permit depending on their route, such as employment, study, family reunification, visitor status, digital nomad status, long-term residence or permanent residence. A Cyprus residence permit does not automatically create Cyprus tax residency, and Cyprus tax residency does not by itself grant immigration residence rights.

Citizenship

Citizenship in Cyprus is obtained by the main routes of naturalisation by residence, marriage/civil partnership to a Cypriot, and Cypriot origin/descent. Cyprus no longer has a citizenship-by-investment “passport” programme.

Cypriot citizenship by naturalisation through residence generally requires seven years of lawful residence in Cyprus within the previous ten years, plus a continuous 12-month period of residence immediately before submitting the application, and the fulfilment of additional conditions, including good character, a clean criminal record, sufficient knowledge of the Greek language, financial self-sufficiency, suitable accommodation, integration into Cypriot society, and an intention to continue residing in Cyprus.

Highly skilled employees may apply under a fast-track naturalisation route, under which they may obtain Cypriot citizenship after four years of lawful residence, or three years depending on their level of Greek language proficiency (A2 or B1 respectively), plus a continuous 12-month period of residence immediately before applying. Applicants must also meet requirements of good character, sufficient knowledge of Greek and of the basic political and social reality of Cyprus, suitable accommodation, adequate and stable financial resources for themselves and their family members, and an intention to reside in the Republic.

Citizenship by marriage or civil partnership is available to foreign spouses of Cypriot citizens after three years of marriage or civil partnership, provided that the couple has resided in the Republic for at least two years, with residence in Cyprus for at least six months in each year and an overall stay of not less than two years during the three-year period immediately preceding the application. Where the couple resides abroad, different conditions apply, including a requirement to explain the reasons for applying for Cypriot citizenship.

Citizenship by Cypriot origin or descent is available to individuals with a Cypriot parent and in some cases through an earlier generation. Eligibility depends on factors such as the applicant’s date of birth, parentage, and whether the relevant provisions apply before or after Cyprus gained independence on 16 August 1960. Applicants usually need identity documents, birth certificates, evidence of the Cypriot parent’s citizenship, and legalised or apostilled foreign documents.

Cyprus no longer offers direct citizenship by investment. The former Citizenship by Investment Programme (CIP), which granted citizenship through investment, was suspended in 2020.

The alternative route through investment is the Cyprus Golden Visa, however, this relates only to residence permit and not citizenship. The only available route for obtaining citizenship is outlined in 7.1 Requirements for Domicile, Residency and Citizenship. 

Residency by Investment (“Golden Visa”)

• Minimum investment: EUR300,000 in new residential property or other approved investments.
• Requirements: clean criminal record, proof of foreign income, and retention of the investment required.
• Family eligibility: includes spouse, children, parents.
• Processing time: approximately two to six months.
• Citizenship after residency: investors may apply for citizenship only through naturalisation, not through investment. A key requirement is seven years of legal residence.

Cyprus currently offers no fast-track or investment-based route to citizenship. The only viable way is investment-based permanent residency, followed by ordinary naturalisation after sufficient years of residence.

Cyprus does not have a statutory “special-needs trust” regime. Families rely on CITs and court-supervised guardianship to protect assets and ensure long-term care for minors and adults with disabilities.

• CITs: CIT are the main legal mechanism to provide financial security for vulnerable persons. CITs allow: (i) discretionary distributions tailored to care needs, (ii) long-term management by professional trustees, (iii) protection from family conflict or mismanagement, and (iv) ring-fencing of assets for lifetime support.

In general, property rights vested on a minor and/or property which registered in the name of a minor cannot be sold transferred, mortgaged, invested or liquidated, without the approval and the oversight of the Family Court. As a matter of practice, the Court will only grant such an approval if the transaction is in the interest of the minor.

• The management of the property interests of a minor is exercised by both parents, or the sole surviving parent. In the case of death of both parents and/or in case where the surviving parents lack the capacity to exercise the parental care of the minor and/or in the event that the court decided to remove the duty of parental care from the parents, a guardian is appointed by the court who undertakes the task of managing the property of the minor.

• Guardianship (court supervision): the court may appoint a guardian for minors, as explained above, or adults lacking capacity. The guardian manages personal and financial affairs under judicial oversight. However, it is very bureaucratic and less flexible than trust-based planning.
• Public law disability protections: Cyprus has a strong rights-based disability framework (National Action Plan on Disability, EU-aligned policies). These ensure access to services, education, and social support, but do not create a private wealth-management structure

Any appointment of a financial guardian requires a court order, and the guardian’s management of money or property is continuously supervised by the court.

• Court appointment is mandatory: a District Court must appoint a judicial guardian before anyone can legally manage a minor’s or incapacitated adult’s bank accounts, property, investments, or business interests.
• Strict financial oversight: the guardian must (i) submit regular financial reports and account statements, (ii) obtain court approval for major transactions (sale of property, investment decisions, withdrawals etc), (iii) act under continuous judicial monitoring to prevent misuse of assets.
• Criteria and exclusions: the court evaluates the proposed guardian’s financial competence, integrity, and absence of conflicts of interest. Persons with financial misconduct, or conflicting personal interests are typically excluded.
• Why families avoid guardianship for financial matters: because the system is bureaucratic and heavily supervised, families often use CITs to manage assets for minors or vulnerable adults without ongoing court control.

Cyprus has no lasting power of attorney (PoA). Ordinary PoAs end once the person loses capacity so they cannot be used for long-term incapacity planning. To legally plan for future mental incapacity, residents use court-appointed administration governed by Administration of Property of Incapacitated Persons Law (Law 23(I)/1996) and trust structures.

• Incapacity: formal mechanism is a court-appointed administrator/guardian to manage the person’s property, bank accounts, and financial affairs. Appointment requires medical evidence, and the administrator is under strict court supervision (regular accounts, approvals for major transactions).
• Use of CITs: families use CITs to ensure a continuous financial management without court involvement.

Families prepare financially for longer lives through three main pillars.

• Pensions and savings: occupational and private pension schemes, plus tax advantaged retirement and life insurance products, are increasingly used.
• CITs: promoted and used as a long-term wealth structuring tool to ring-fence assets, fund future care, and preserve family wealth across generations.
• Intergenerational planning: lifetime gifts and family holding structures are common, facilitated by the absence of inheritance and gift tax, allowing assets to be positioned in advance for multi-generational support.

In Cyprus, children born out of wedlock are viewed and treated as if they were children born into a valid marriage. Once paternity is established, they have full inheritance rights from both parents. Likewise adopted children have the same inheritance and succession rights with regards to their adoptive parents as biological children, however once adopted, their rights from their biological parents will cease.

Furthermore, surrogacy is permitted in Cyprus under a court-approved regime. A pre-birth court order designates the intended parents as the legal parents. The child is treated as a biological child of the intended parents would be, with full inheritance rights through them and not from the surrogate mother.

Cyprus does not recognise same-sex marriage, but it does recognise same-sex civil partnerships under Law 185/2015. A registered civil partnership gives partners spousal equivalent rights for property, inheritance, next of kin status and tax treatment. With no inheritance or gift tax in Cyprus, transfers between civil partners are tax neutral.

Unregistered same-sex couples have no automatic rights, so planning relies on wills, CITs, co-ownership, life-insurance beneficiaries and powers of attorney.

Cyprus does not recognise de facto cohabitation as creating any legal rights. Unmarried partners have no automatic inheritance, property, tax or next of kin status, unlike married couples or registered civil unions.

Because the law provides no default protections, unmarried couples must rely on private planning, namely:

• wills (essential, as partners inherit nothing under intestacy);
• CITs (long-term protection outside statutory heirs);
• co-ownership of property/assets;
• life insurance beneficiary designations; and
• PoAs for medical and financial decisions.

Courts may recognise constructive trust claims only with strong proof of financial contribution, but these rights are not automatic. Couples seeking spousal-equivalent rights can register a Civil Union, which grants inheritance, property and next of kin status (but not adoption).

Cyprus encourages charitable giving through tax incentives, as follows.

• Donations or contributions made for educational, cultural, or other charitable purposes to the Republic, a Local Government Authority, or any charitable institution approved as such by the Council of Ministers are tax deductible to the extent that the taxpayer incurred taxable profits.

Any portion of that loss up to the amount of the donation or contribution shall not be carried forward and shall not be set off against income of subsequent years.

A donation to the Republic and any donation made for educational, cultural, or other charitable purposes to a local authority or to any charitable institution in the Republic that is approved by the Council of Ministers is also exempt from capital gains tax purposes.

• An amount of up to EUR50,000 in respect of donations or contributions made to cultural institutions approved by the Deputy Minister of Culture, subject to such terms or conditions as may be determined by the Council of Ministers, is tax deductible to the extent that the taxpayer incurred taxable profits.

Any portion of that loss up to the amount of the donation or contribution shall not be carried forward and shall not be set off against income of subsequent years.

The term “cultural institutions” includes:

1. public law legal entities;
2. associations or foundations whose principal constitutional/objective purpose is the non-profit research and study of culture and/or the organisation and/or production of non-profit activities.

• The income of a religious, charitable, or educational institution of a public character is exempt from income tax.
• The income of a company established exclusively for the promotion of art, science, or sport, which does not involve the earning of profits by the company or its members and whose activities are restricted solely to that purpose, is exempt from income tax (subject to conditions).

Common Charitable Structures in Cyprus include the following forms, and their relevance/usefulness depends on the size of the charity’s activities and the nature of the activities.

Association

• This is a membership-based, non-profit organisations and it is usually more relevant where a large number of members is involved.
• It is best suited for community organisations, sports clubs, cultural groups, advocacy organisations, and volunteer groups.

Foundation

• Foundations are most suitable toa specific charitable or public-benefit purpose (scholarships, educational, religious, medical or other philanthropic purposes).
• They are typically funded by an endowment or donated assets and do not ordinarily have members.

Non-Profit Company Limited by Guarantee

• These companies are incorporated and regulated under the Cyprus Companies Law.
• They do not have shareholders but the members guarantee a nominal amount if the company is wound up.
• These companies are very often used by larger charities, NGOs, educational organisations, and research institutes and, in general, when looking to establish a professional NGO which will be seeking grants.

Trust

• A trust can be established for charitable purposes.
• The trustees will hold and manage assets for the benefit of the charitable purpose. Trusts are ordinarily used for the management of endowments, family philanthropy, or specific charitable funds rather than operating public programmes.