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Tax Memo on Cyprus IP Holding Structure & Tax Optimization

IP Structuring and Tax Optimisation Using Cyprus Incentives


Our Work

We undertook a project to advise on and prepare a tax memo regarding the creation of an IP holding structure in Cyprus for tax optimization. Our analysis focused on corporate tax incentives, including the IP Box Regime and Notional Interest Deduction (NID), as well as withholding tax (WHT) obligations in key jurisdictions such as Italy, Switzerland, and China. Based on our findings, we recommended utilizing the NID regime, as it offers a significant reduction in taxable income, while also assessing the potential applicability of the IP Box Regime under specific conditions. Additionally, we provided guidance on economic substance requirements, ensuring compliance with OECD BEPS standards and EU Pillar II rules.