Cyprus: Russia’s deoffshorisation law and Cyprus companies

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Cyprus: Russia’s deoffshorisation law and Cyprus companies

charalambous.jpg

Katerina A Charalambous

Cyprus companies have a long history of presence in Russian structures. Russia's deoffshorisation law and, more specifically, the introduction of controlled foreign company (CFC) rules which was set to prevent the shifting of profits to preferential tax jurisdictions and re-route funds back to Russia could also affect the domination of Cyprus companies in such structures. Nonetheless, as it is construed from the aforementioned legislation, nothing is black and white and each case must be viewed on its own merits. In the same vein, the Russian Ministry of Finance has recently clarified the criteria upon which profits of a Cyprus company shall be exempted from Russian taxation. The Ministry has clarified that companies whose large majority of income (more than 80%) is active shall be exempted. However, the active companies' test is not expected to be straightforward, with the list of passive income to include dividends, interest and royalties as well as rental and lease income and income from the provisions of consulting, marketing, legal and other services.

Further, the Ministry of Finance notes that the effective tax rate test whereby companies registered in jurisdictions which exchange information with Russia and impose an effective tax rate equal to, or higher than, 75% of the average tax rate that would have been imposed in accordance with the Russian tax legislation, must also be considered for the purpose of determining whether the profits of the Cyprus company are exempted from Russian taxation. The exchange of information for tax purposes between the two jurisdictions is accomplished based on the Russia – Cyprus tax treaty (income and capital tax) now in force.

The various international tax developments taking place have also urged Cyprus to re-examine its tax regime to catch up and radical changes could be on the horizon. Legislative changes that are expected to reaffirm Cyprus's attractiveness as an international business centre are expected to be presented to the Council of Ministers and implemented soon.

Katerina A Charalambous (katerina.a.charalambous@eurofast.eu)

Eurofast, Cyprus Office

Tel: +357 22 699 222

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

Advisers with pre-existing corporation tax or self-assessment accounts must now register or risk enforcement action from HMRC
India's tax authorities are increasingly scrutinising the rationale behind cross-border structures
Sharmila Sanmugam's move from industry to WTS UK offers an early glimpse into how the fledgling firm hopes to compete with larger rivals
Historical claims involving KPMG Australia's tax practice have surfaced as the firm battles a separate parliamentary inquiry into its handling of whistleblowers
While AI is revolutionising tax work, it is also reshaping clients’ willingness to pay for advice and their perception of the value generated by tax advisers
From Dhruva Advisors to Svalner Atlas, Ryan is growing fast. Tom Shave discusses consolidation, competition, and tax’s private equity debate
Awards
ITR is delighted to reveal the shortlisted nominees for the Middle East Tax Awards
The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward
Fragmented pillar two taxation and increased use of AI by tax authorities have left clients fearful of heightened disputes exposure
Grant Thornton Advisors’ latest acquisition has produced the fifth-largest US advisory firm by revenue, but there’s still a clear gulf between it and the big four
Gift this article