Cyprus Anti-Avoidance Rules - CFCs

Offshore Tax with HTJ.tax · Oct 15, 2025 · 2m

In this episode, we unpack Cyprus’s Controlled Foreign Company (CFC) Rule — a key anti-avoidance measure that ensures profits shifted to low-tax jurisdictions remain subject to taxation where real economic activity occurs.We explain how Cyprus applies its CFC rule under the EU Anti-Tax Avoidance Directive (ATAD), what counts as a “non-genuine arrangement,” and when exemptions apply.🧩 Key Topics CoveredPurpose of the RuleThe CFC regime is designed to counteract profit shifting to subsidiaries in low-tax jurisdictions.➤ In essence, if a Cypriot company controls a foreign entity that exists…