Australian businesses and private individuals are increasingly looking to Cyprus as an entry point into the European Union. The appeal is straightforward. A competitive tax environment, a legal system rooted in English common law, and a business culture that is comfortable working with foreign, non-resident owners and directors.
The interest spans for more than one type of client. Australian businesses use Cyprus as a stepping stone into EU markets; investors and family offices are drawn to its residency pathways and its trust and succession framework. Australian individuals relocating or restructuring their affairs are attracted by a tax regime that rewards genuine, well-documented residency rather than complex domestic planning. Company registration activity in Cyprus has remained strong in recent years, reflecting sustained demand from foreign founders and investors, Australians increasingly among them.
Documents issued in Australia need to be properly authenticated before Cyprus authorities will accept them, and genuine local substance — not simply a registered address — matters for tax residency purposes. The sections that follow set out what Cyprus actually offers, structured around the questions we are asked most often by clients and their advisers, from Australia.
Tax Advantages at a Glance
Cyprus combines one of the most competitive tax frameworks in the EU for companies with one of the most favourable regimes in Europe for internationally mobile individuals. The sections that follow cover each in more detail.
For Companies
For Individuals (Non-Domiciled Tax Residents)
For Trusts & Structures
Cyprus Company Formation
Cyprus remains one of the most established EU jurisdictions for holding, trading, and IP-holding structures, combining a competitive tax framework with full access to the EU single market.
Typical Structures
Holding companies
for EU-facing investments or subsidiaries
IP holding vehicles
for businesses expanding into European markets
Investment holding structures
consolidating international assets
Joint venture or trading vehicles
for EU market entry
Why Cyprus for Company Formation
Regulatory Framework
Cyprus company incorporation and administration is governed by the Cyprus Companies Law (Cap. 113) and supervised by the Registrar of Companies. Corporate administration services are regulated under the Regulation of Administrative Service Providers Law of 2012, requiring licensing by the Cyprus Securities and Exchange Commission (CySEC).
Oneworld Limited, a member of the Oneworld Group, is a licensed Administrative Service Provider under the 2012 Law, authorized to provide company formation, administration, and directorship services. Licence No. 149/196.
The 60-Day Rule
Cyprus is one of the few jurisdictions where an individual can become tax resident without spending most of the year there.
Qualifying Conditions
Why This Matters
It allows EU tax residency to be layered onto an existing life and business base elsewhere — a fit for internationally mobile executives, investors with EU interests, and individuals planning ahead of a relocation or a major liquidity event.
Headline Benefits Once Resident (Non-Domiciled Status)
The Cyprus International Trust
The CIT is built on English common law principles under the Trustees Law (Cap. 193) and the International Trusts Law of 1992 (as amended in 2012) — familiar territory for common law-trained advisers and clients.
Formation & Requirements
The settlor and beneficiaries must not have been Cyprus tax residents in the year preceding formation. At least one trustee must be a permanent Cyprus resident throughout the trust’s life.
Legal Strength & Protection
Foreign succession rules, forced heirship provisions, or foreign court judgments do not affect the validity of a CIT. Validity can only be challenged on grounds of fraudulent transfer, within two years of that transfer.
Confidentiality
Trustees are bound by strict confidentiality and may not disclose information about the trust, settlor, or beneficiaries except where required by law or court order.
Reserved Powers & Flexibility
A settlor may retain specific powers without affecting validity: revoke or amend the trust, instruct trustees, appoint or remove trustees and protectors, change governing law, or migrate the trust’s seat.
Duration, Taxation & Trust Types
Key Benefits of a Cyprus Trust
Where This Fits
Duration & Taxation
A CIT may have unlimited duration, with income and gains accumulating without time restriction unless the trust deed provides otherwise.
Trustees are not taxed on trust income or gains in their capacity as trustee. Non-Cyprus-resident beneficiaries are taxed only on Cyprus-source income. There is no Cyprus estate/inheritance duty on asset transfers via trust.
Trust Types Available
Discretionary Trusts
Most common — maximum flexibility for trustees over distribution
Charitable Purpose Trusts
Capital used exclusively for charitable or public-benefit purposes
Interest in Possession Trusts
A named beneficiary holds an absolute right to trust income
Fixed Interest Trusts
Pre-determined terms set by the settlor for a named beneficiary
The 2026 Tax Reform & Treaty Position
Cyprus implemented its most significant tax reform in two decades, effective 1 January 2026 — a natural, timely reason to raise Cyprus in a client conversation.
Key Changes
Cyprus vs Australia — Tax Residency
| Cyprus | Australia | |
|---|---|---|
| Corporate Taxation | ||
| Corporate tax rate | 15% flat, all companies | 30% standard; 25% for “base rate entities” (turnover < AUD $50m, ≤80% passive income) |
| Capital gains (companies) | Exempt on disposal of securities; CGT applies only to Cyprus immovable property (or shares deriving value from it) | Included in assessable income; taxed at the 30%/25% corporate rate, no discount |
| Dividend withholding (outbound) | None on dividends paid to non-resident shareholders | Generally none on fully franked dividends; up to 30% on unfranked, subject to treaty relief |
| Individual Taxation | ||
| Residency threshold | 60 days + conditions | Resides / domicile / 183-day / superannuation tests |
| Personal tax-free threshold | €22,000 (2026 reform) | AUD $18,200 |
| Top marginal personal rate | Progressive, with non-dom exemptions on passive income | 45% (income over $190,000) + 2% Medicare levy |
| Dividend / interest income | Exempt for qualifying non-dom residents (~17 years) | Taxed at marginal rate (worldwide income) |
| Capital gains (individuals) | Exempt on disposal of securities | Included in assessable income at marginal rate; 50% CGT discount if asset held over 12 months |
| Inheritance / estate tax | None | None — Australia has no federal inheritance or estate tax |
| Double tax treaty between the two | Not currently in force (see previous page) | Not currently in force (see previous page) |
Note: figures above reflect Australian tax residents. Australian non-residents face different rules — no tax-free threshold, a flat 30% rate on income up to $135,000 (then 37%/45%), and tax generally limited to Australian-sourced income and gains.
This table is a high-level illustration for adviser discussion purposes only, based on publicly available rates and thresholds as of September 2026. Individual circumstances — residency history, entity structure, asset location, and applicable elections — materially affect the actual tax position in either jurisdiction, and rates and thresholds are subject to change by either government. This is not a substitute for individual tax advice from a qualified adviser in Cyprus and/or Australia.
Your One-Stop Shop for Cyprus
Oneworld is a licensed fiduciary services group offering the full range of services a client needs to relocate to, invest in, or structure through Cyprus — coordinated under one roof, with a single point of contact throughout.
40+
Years serving international clients
149/196
Oneworld Group CySEC licence
Residency and citizenship programmes, permit applications, and relocation support.
Accounting, VAT and regulatory compliance, international tax advisory, and IFRS reporting.
Company formation, administration, directorship, and registered office services.
Cyprus International Trusts, trustee services, and succession structuring.
Fund set-up and ongoing administration for investment structures.
In-house legal capability across corporate, regulatory, and private client matters.
Getting Started
Cyprus continues to attract individuals and businesses seeking EU tax residency, trust and succession structures, and company formation within a common law-influenced legal system. Oneworld has supported international clients with Cyprus structuring for over 40 years — company formation, tax residency applications, trust and fiduciary services, and ongoing compliance and administration.
If you are considering Cyprus for tax residency, trust planning, or company formation, we’d welcome the opportunity to discuss your circumstances.
75 Prodromou Avenue, Oneworld Parkview House, 2063 Nicosia, Cyprus · info@oneworldweb.net · +357 22 496 000 · www.oneworldweb.net
