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

The country has overseen better audit procedures and demonstrated commitment to acting as a 'regional leader' on international tax matters, the OECD said
Barrister Setu Kamal and policy guru Dan Neidle have clashed over the former’s legal action against Google, described as ‘bonkers’ by Neidle
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
Dual-qualified corporate tax specialist Christoph Schimmer joins the firm after stints at Deloitte, Cerha Hempel and DLA Piper
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
LED Taxand’s partner tells ITR about entrepreneurial inspirations, the importance of people skills, and what makes tax cool
Shiny new offices like Ryan’s in London Bridge aren’t just a cost – they signal that a firm is willing to align with its clients’ interests
Darren Graves will succeed Richard Houston, who is set to lead Deloitte EMEA; in other news, Morgan Lewis hired a three-partner tax team in New York
India also signed its first-ever bilateral APAs with France, Ireland, Indonesia and Sweden last year, the CBDT revealed
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
Gift this article