Cyprus: Domestic Corporate Taxation
Branch or Subsidiary?
Corporation tax rates are the same, but the calculation of the taxable base is different:
- Head-office expenses are allowable in both cases
- Transfer-pricing rules may be applied differently in the two cases
- Branch profits may be remitted to head office free of withholding tax; corporate dividends are also now exempt from withholding tax
- Interest on intercompany loans is generally deductible for a company, but not for a branch.