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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.



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