09.24

PE Risk Advisory for U.S. DaaS Provider Establishing Cyprus Branch

Advising a U.S. Tech Group on Tax Presence in Cyprus


Our Work

We advised our client, a Data as a Service (DaaS) provider headquartered in the United States with operations in a European country, on the Permanent Establishment (PE) risk in Cyprus. The company is establishing a Cyprus branch to serve an international client base (excluding the U.S.) and sought guidance to ensure that no taxable presence is created in Cyprus for the parent entity. Our analysis covered the tax residency risk, the application of the Cyprus–U.S. Double Tax Treaty, the use of office space, and the activities of the company’s CEO in Cyprus. Additionally, we provided strategic mitigation measures to ensure that management and control of the U.S. entity remain outside Cyprus, while also advising on the CEO’s personal tax obligations and potential eligibility for first employment tax incentives in Cyprus.