Cyprus CFC rules y imposición de sociedades extranjeras controladas según la ley alemana: Estructuras legales seguras a pesar de la obligación tributaria en Alemania – Estrategias avanzadas de cumplimiento normativo

Why CFC-rules dont have to end your Cyprus adventure

Let me start with a story from last week:

An entrepreneur calls me. Totally distraught. His tax consultant had just told him that his planned Cyprus-structure was “impossible” because of the German CFC-rules. The tax office would intervene immediately. He should better keep everything in Germany.

Here’s the twist:

This statement is simply wrong. At least, it’s incomplete.

Yes, the German CFC-rules (Controlled Foreign Company rules) are real. And yes, they can affect your Cyprus-structure. But no, they do not make legally compliant international tax planning impossible.

The problem lies elsewhere:

Most tax consultants only understand CFC-rules superficially. They see the regulation and think: “Too complicated, too risky.” Yet there are definitely legal ways for you to benefit from Cyprus’s advantages despite German tax residency.

In this article, I’ll show you exactly these ways. Not as theoretical gimmicks, but as practicable strategies. Because one thing is clear: Whoever understands the rules, can use them in accordance with the law.

Are you ready for a deep dive into the world of international compliance? Then let’s shed some light on the darkness surrounding CFC-rules together.

Yours, RMS

Understanding CFC-rules: The mechanism behind Germany’s tax hammer

Before we get to the solutions, you need to understand what we’re dealing with. CFC-rules are the sharpest sword of the German tax authority against international tax planning.

What are CFC-rules, anyway?

CFC stands for Controlled Foreign Company. The principle is simple: Germany wants to prevent you from “parking” profits in low-tax countries and bringing them to Germany only later.

The logic behind this: If you control a foreign company and it only earns passive income, Germany treats this income as if you had earned it directly in Germany.

Sounds complicated? It is. But once you understand it, completely new opportunities open up.

When do the German CFC-rules apply to Cyprus?

The German CFC-rules apply under § 7 AStG (Foreign Tax Act) if three conditions are met:

• Control: You (directly or indirectly) own more than 50% of the Cypriot company
• Low taxation: The tax burden in Cyprus is less than 25% (which is often the case in practice)
• Passive income: More than 10% of the gross income is passive (interest, license, certain rents)

If all three points apply, Germany adds your Cyprus company’s profits to your German income. As if you had earned the profits directly in Germany.

The result: German tax liability despite the Cyprus-structure.

The difference between active and passive income

This is the key to understanding: CFC-rules primarily target passive income. These include:

This means: If you run an active operational business through your Cyprus company, CFC-rules often do not apply. But caution – the tax office looks very closely at what is actually active.

The EU exception: Your shield against CFC-rules

This is where things get interesting for Cyprus: As an EU member state, Cyprus enjoys special protection. The CFC-rules may not violate the right of establishment.

Specifically, this means: If your Cyprus company has real economic substance, you can refer to EU fundamental freedoms. The tax office must then prove that your structure exists only for tax avoidance.

And this is exactly where the legally compliant strategies I am about to present come into play.

German CFC-taxation: When the tax office strikes

Let me be honest: German CFC-taxation is not a paper tiger. It has already destroyed many international structures. But it is also not an insurmountable obstacle.

The trick is to understand when and how it is applied.

The CFC taxation mechanism

Imagine you have a Cyprus company with €100,000 profit. Normally, you pay 12.5% corporate tax in Cyprus, i.e. €12,500. So far, so good.

If, however, the CFC-rules apply, the following happens:

1. Germany adds the €100,000 to your personal income
2. You pay the German income tax rate (up to 45% + solidarity surcharge)
3. The €12,500 paid in Cyprus is credited
4. You pay the difference in Germany

Result: Instead of 12.5%, up to 47% effective tax burden. Your Cyprus-structure becomes worthless for tax purposes.

Timing of CFC-inclusion: Immediately, not just upon distribution

Here’s another pitfall: The CFC-inclusion happens immediately when profits are generated, not only when dividends are paid. This distinguishes CFC-rules from normal foreign tax provisions.

In practice this means: Even if your Cyprus company retains its profits, you have to pay tax in Germany. You have a cash outflow before any cash inflow.

This is why it is essential to develop legally compliant structures from the outset.

Exemptions: Your legal loopholes

The German Foreign Tax Act provides for various exemptions from CFC-taxation. The most important ones for Cyprus-structures:

The 10% test for passive income

If passive income makes up less than 10% of gross receipts, CFC-rules do not apply. This is often easier to achieve than one might think.

Example: Your Cyprus company generates €500,000 operational revenue and €40,000 interest. The interest makes up only 7.4% – CFC-rules do not apply.

Real pursuit of economic activity

If your Cyprus company conducts real economic activity, it can be exempt from CFC-rules. Real means:

• Own personnel on site
• Own office premises
• Independent business decisions
• Substantial local activities

This works especially well for consulting, IT or trading companies.

The EU proof of business purpose

As an EU member state, Cyprus can rely on the right of establishment. You must then prove that your company was not established solely for tax avoidance.

If you succeed, CFC-rules don’t apply – even with low taxes and passive income.

Cyprus as an EU tax location: Between dream and reality

Let’s get to what really interests you: Why is Cyprus still one of the most attractive EU tax locations despite CFC-rules?

The secret lies in its unique mix of low taxes, EU advantages and practical structuring possibilities.

The tax advantages of Cyprus in detail

Cyprus offers far more than just 12.5% corporate tax. The complete package makes the difference:

Especially the 0% dividend tax makes Cyprus an interesting holding location. Even if CFC-rules apply, you can still optimize structures.

EU advantages that Germany cannot ignore

As an EU member, Cyprus enjoys rights that Dubai or other locations do not have:

• Right of establishment: Protection from discriminatory tax rules
• EU directives: Parent-Subsidiary Directive, Merger Directive
• Double tax treaties: Over 60 treaties worldwide
• Anti-BEPS compliance: Internationally recognized standards

This means: German authorities cannot simply say “Cyprus is bad”. They must demonstrate concrete tax avoidance.

The reality: Substance requirements are rising

But let me be honest: The days of simple mailbox companies are over. Cyprus now requires real substance:

Minimum requirements for Cypriot companies

• Local managing director (can be non-Cypriot)
• Annual shareholders meeting in Cyprus
• Cypriot accounting and tax filing
• Proof of economic activity
• Compliance with economic substance requirements

Sounds like a lot of work? At first, yes. But it makes your structure legally robust – even against German CFC-rules.

Cyprus’s IP Box: An insider tip for digital entrepreneurs

This is exciting for everyone working with intellectual property: The Cyprus IP Box regime allows effective 2.5% taxation on qualifying IP income.

This is how it works:

1. You develop or acquire qualifying intellectual property
2. This is managed in Cyprus (substance required!)
3. Royalty income is taxed at only 2.5%
4. 80% deduction from the regular 12.5% tax rate

And the best part: IP Box income often counts as active income if you can prove genuine development activity. CFC-rules often do not apply then.

Developing legally compliant Cyprus-structures despite CFC-rules

Now we get to the heart of the article: How do you set up your Cyprus-structure so that it works even with German tax residency?

The answer lies in the clever combination of substance building, proof of activity, and EU legal safeguards.

Strategy 1: Operating business activity in Cyprus

The safest way to avoid CFC-rules is real operational activity in Cyprus. That means more than just administration – you have to show value-creating activities.

Practical implementation for different business models:

For IT entrepreneurs:

• Build a development team in Cyprus
• Software development and maintenance on site
• Customer support from Cyprus
• Local servers and infrastructure

For consultants and coaches:

• Provide consulting services directly from Cyprus
• Local staff for administration
• Acquire Cypriot clients
• Conduct training in Cyprus

For e-commerce entrepreneurs:

• Warehousing and logistics in Cyprus
• Local marketing and sales team
• Product development on site
• EU-wide sales from Cyprus

What counts: Activities must be real and provable. A couple of emails per month is not enough.

Strategy 2: The EU-substance structure

This strategy cleverly uses the EU right of establishment. You build real substance in Cyprus, which can override CFC-rules even without active business.

The three pillars of EU substance:

1. Personnel substance: Local managing director with real authority
2. Spatial substance: Own office premises (not just a postal address)
3. Functional substance: Independent business decisions

In practice, for example:

You set up a Cypriot management company coordinating your German and international activities. A local MD makes independent decisions on investments, partnerships, and business development. The company has its own offices and conducts regular board meetings.

This structure can also work with passive income if you prove that the company is not only for tax avoidance.

Strategy 3: The smart activity mix

Here you take advantage of the 10% test. You make sure passive income stays under 10% by intentionally generating active income.

A practical example:

Result: Passive income is only 8%. CFC-rules do not apply, even though you have considerable passive income.

The trick: Plan the mix from the beginning, not as an afterthought.

Strategy 4: The Double-Irish-Dutch alternative

This more complex structure uses several EU locations to circumvent both CFC-rules and other tax pitfalls.

Basic structure:

• German operating company: Runs the operating business
• Cyprus holding: Holds IP rights and investments
• Irish licensing company: Manages and develops IP further
• Dutch intermediary holding: Optimizes withholding tax

Each company has real functions and substance. Result: Total tax burden under 15%, fully EU compliant and CFC-proof.

But beware: These structures are complex and require professional support. They are worth it only at certain profit sizes.

Advanced compliance strategies for international entrepreneurs

Let me be clear: Legal security does not result from tricks or loopholes. It results from meticulous compliance and professional documentation.

Here Ill show you how to build your Cyprus-structure so that it stands up to even the toughest tax audits.

The golden rules of international compliance

Rule 1: Document everything

The German tax office has a reversed burden of proof for international structures: You must prove everything is legal. Complete documentation is vital for survival.

What you need to document:

• Business reason for the Cyprus structure
• Independent business decisions of the Cypriot company
• Proof of substance (personnel, premises, activities)
• Arm’s length conformity of all transactions
• Complete bookkeeping in Cyprus and Germany

My tip: Keep a “substance diary”. Regularly document all activities in Cyprus – from meetings to decisions.

Rule 2: Plan substance from day one

Substance cannot be created thereafter. You must build it from foundation and expand it continuously.

Substance plan for the first year:

1. Month 1-2: Incorporation with local managing director
2. Month 3-4: Renting own office
3. Month 5-6: Hiring first local employees
4. Month 7-8: Building operational activity
5. Month 9-10: First Cypriot client contracts
6. Month 11-12: Documentation and evaluation

Substance costs money. But it’s cheaper than an audit with CFC back payments.

Transfer pricing: The underestimated compliance pitfall

Many international structures fail here: They forget to document transfer prices between their companies.

The German tax office automatically checks for arm’s length pricing in international structures. If you can’t prove it, painful corrections are looming.

Practical transfer pricing compliance:

For royalties:

• Obtain an IP valuation by experts
• Document development costs
• Conduct regular benchmarks
• Use recognized valuation methods

For management fees:

• Define clearly the services rendered
• Provide evidence of time spent
• Compare with market rates
• Create detailed service agreements

For loan interest:

• Conduct a creditworthiness check
• Document alternative financing options
• Use market interest rates
• Create professional loan agreements

The country-by-country reporting trap

Above certain revenues, multinational companies must prepare detailed country reports. The threshold is lower than many think: €750 million group revenue.

But even below that, you should be prepared. Transparency requirements are increasing continuously.

What you should document already:

• Turnover and profits per jurisdiction
• Number of employees per location
• Taxes paid per country
• Main activities per company
• Assets per jurisdiction

This data helps not only with compliance but also with optimizing your structure.

The anti-BEPS compliance checklist

The OECD BEPS initiative (Base Erosion and Profit Shifting) has fundamentally changed international tax rules. Your Cyprus-structure must be BEPS compliant:

Each measure has specific requirements. If you ignore one, your whole structure is at risk.

Practical implementation: From theory to a working structure

Enough theory. Let’s get practical. How do you actually build a legally secure Cyprus-structure?

Ill show you three proven implementation scenarios – from simple to complex.

Scenario 1: The solo consultant

Initial situation: Thomas, 36, German consultant with €400,000 annual turnover. Wants to reduce his tax rate from 42% to below 20%.

Solution: Operational Cyprus company with real business activity

Step-by-step implementation:

1. Preparation (2 months):
   • Tax analysis of current situation
   • Selection of suitable Cypriot partners
   • Preparation of business relocation
2. Incorporation (1 month):
   • Founding Cyprus Consulting Ltd.
   • Registration with Cypriot authorities
   • Opening business account
3. Building substance (3 months):
   • Renting office in Limassol
   • Hiring local assistant
   • Relocation of customer support to Cyprus
4. Operational phase (from month 6):
   • Acquisition of Cypriot and international clients
   • Providing consulting from Cyprus
   • Ongoing substance expansion

Result: Effective tax burden 15% (12.5% corporate tax + costs). CFC-rules do not apply due to real operative activity.

Investment: About €40,000 in the first year for substance. Savings: Around €100,000 per year.

Scenario 2: The e-commerce company with IP-structure

Initial situation: Elena, 42, e-commerce entrepreneur with her own software system. €2 million revenue, high royalty income.

Solution: IP box optimized structure with Dutch intermediary holding

Structure setup:

• Germany: Operations GmbH (operational activities)
• Netherlands: Holding B.V. (intermediate holding)
• Cyprus: IP Holdings Ltd. (IP management and development)

How it works:

1. German GmbH pays royalties to Dutch B.V.
2. B.V. passes on royalties to Cypriot IP Holdings
3. IP Holdings develops software further and manages the IP portfolio
4. Profit is taxed via IP box at 2.5%

Substance requirements:

• Development team in Cyprus (3 people)
• Own office premises with development infrastructure
• Local IP manager with real authority
• Continuous software development

Result: Total tax burden below 10% on IP-income. Full CFC-resistance due to real development activity.

Scenario 3: The complex corporate group

Initial situation: Robert, 45, group of companies with various entities, €15 million group turnover.

Solution: Multi-jurisdictional structure with central Cypriot holding

Structure diagram:

Cyprus Ultimate Holding Ltd. (Cyprus)
├── German Operations GmbH (Germany)
├── Dutch Finance B.V. (Netherlands)
├── Irish IP Holdings Ltd. (Ireland)
└── UAE Trading LLC (Dubai)

Each company has specific functions and real substance. The Cypriot holding coordinates the group and optimizes capital flows.

Compliance costs: Considerable, but economically sensible at this level. Country-by-country reporting required.

Tax saving: About €2-3 million per year if executed correctly.

The critical success factors

No matter which structure you choose, there are five critical success factors:

1. Real substance: No mailbox companies, only operating businesses
2. Business rationale: Clear business reasoning for the structure
3. Professional support: Experienced advisors in all jurisdictions
4. Continuous compliance: Ongoing monitoring of all requirements
5. Flexibility: Ability to adjust to legal changes

If you neglect any of these factors, you endanger the entire structure.

Smart combinations: Cyprus + Dubai + Germany

This is where it gets really interesting: Combining different jurisdictions can maximize tax advantages while minimizing CFC risk.

Let me show you how to combine Cyprus smartly with other locations.

The Cyprus-Dubai combination

Dubai and Cyprus complement each other perfectly: Dubai for operating business, Cyprus for EU access and holding functions.

Structure model Mediterranean Bridge:

• Dubai FZE: Business activity, 9% corporate tax
• Cyprus Holding Ltd.: EU holding, IP management, 12.5% on active income
• German GmbH: Local activities as required

How it works:

1. Dubai FZE provides operating services (consulting, IT, trade)
2. Cyprus Holding licenses IP to Dubai FZE
3. Profits flow via dividends to Cyprus (0% withholding tax)
4. Cyprus Holding optimizes further profit distribution

CFC protection: Dubai company is operationally active, Cypriot holding has EU shield. Double insurance against German CFC-rules.

The Cyprus-Malta combination

Malta offers unique tax benefits for certain activities. Combined with Cyprus, interesting optimization options arise.

Structure model Mediterranean Triangle:

• Malta Trading Company: Trading activities, 35% nominal but 5% effective
• Cyprus Finance Ltd.: Finance company, 12.5%
• Cyprus Ultimate Holding: Group holding, dividend exemption

Malta’s refund system drastically reduces the effective tax burden. Cyprus optimizes group-wide profit distribution.

The Cyprus-Ireland combination

Ireland is the premium location for IP structures. Combined with Cyprus’s flexibility, highly efficient structures emerge.

Structure model Celtic-Mediterranean IP Structure:

• Irish Development Company: IP development, research deduction
• Cyprus IP Holdings: IP licensing, IP box (2.5%)
• Cyprus Management Company: Coordination and control

Special feature: Ireland’s research deduction reduces development costs. Cyprus’s IP box optimizes royalty taxation. Perfect teamwork.

The limits of smart combinations

But beware: Complexity has a price. Multi-jurisdictional structures only make economic sense beyond a certain size.

Minimum sizes for different structures:

So my advice: Start simple and gradually increase complexity. An over-optimized structure without sufficient profits is wasted money.

Future trends in international structures

International tax planning is evolving rapidly. Trends to watch:

• Digital Nomad regimes: Portugal, Estonia, Barbados are creating new options
• Pillar Two (15% minimum tax): Affects large companies, but trend towards smaller structures too
• Substance requirements: Continuously being tightened
• Automatic exchange of information: Transparency continues to rise
• Brexit aftermath: UK is becoming attractive again for certain structures

Successful international tax planning today means: Flexibility and constant adaptation.

The 7 most common mistakes in Cyprus-structures

Let me be honest: I’ve seen countless failed Cyprus-structures in recent years. Usually, it was the same mistakes that led to their downfall.

Here are the seven most common – and how to avoid them.

Mistake 1: Underestimating substance

The mistake: “I’ll quickly set up a Cyprus company and immediately save taxes.”

The reality: Without real substance, your structure is worthless. The German tax office sees through mailbox companies immediately.

The solution: Plan substance from day 1. At minimum:

• Local managing director with real authority
• Own offices (not just a postal address)
• Independent business decisions
• Verifiable local activities

Cost: €20,000-40,000 per year. But cheaper than a CFC back payment with interest.

Mistake 2: Ignoring transfer pricing

The mistake: Intra-group transfer prices are set “by feel”.

The reality: The tax office corrects non-arm’s-length prices. The consequences can be disastrous.

Example: You pay €50,000 royalties to your Cyprus company. The tax office says: “Market would be only €20,000.” Correction: €30,000 extra German profit plus 42% tax = €12,600 back payment plus interest.

The solution: Professional transfer pricing documentation from the outset.

Mistake 3: Misjudging CFC-rules

The mistake: “Cyprus is in the EU, so CFC-rules don’t apply.”

The reality: Even EU companies are subject to CFC. EU status only protects if there are real business reasons.

The solution: Detailed CFC analysis before structuring. Check:

• Degree of control (>50%?)
• Effective tax burden (<25%?)
• Proportion of passive income (>10%?)
• Available exemptions

Mistake 4: Sham business activity instead of real activity

The mistake: Thinking that a few monthly emails from Cyprus count as “business activity”.

The reality: The tax office spots fake activities. Consequence: Entire profits moved to Germany for tax.

Warning signs for sham business activity:

• Managing director without real authority
• All key decisions made in Germany
• No local customers or suppliers
• Unreasonably high margins without performance

The solution: Build real business operations, don’t just simulate them.

Mistake 5: Complexity without benefit

The mistake: Over-optimized structure with 5+ companies for medium profits.

The reality: Complexity costs more than it saves. And increases risk exponentially.

Rules of thumb for structure complexity:

• Under €500,000 profit: Simple structure
• €500,000-2 million: Moderate complexity
• Over €2 million: Complex structures possible

The solution: Start simple. Grow into complexity.

Mistake 6: Neglecting compliance

The mistake: Failing to keep up compliance after incorporation.

The reality: Compliance violations make even the best structure worthless.

Critical compliance points:

• Proper Cypriot bookkeeping
• Timely tax filings
• Proof of economic activity
• Transfer pricing documentation
• German notification requirements

The solution: Establish professional compliance processes from the beginning.

Mistake 7: Forgetting the exit strategy

The mistake: No-one thinks about how to later dissolve the structure.

The reality: Winding up a structure the wrong way can trigger massive back taxes.

Example: Dissolving a Cyprus company can bring hidden reserves under German tax. Without planning, you face 42% tax on profits you thought already taxed.

The solution: Think about exit strategies from the start. Build flexibility.

The cost factor of failed structures

A real example: An entrepreneur built a “cheap” Cyprus-structure with no substance. Annual cost: €8,000.

The tax office discovered the structure. The bill:

• CFC back tax: €180,000
• Interest: €45,000
• Penalty: €20,000
• Lawyer and consultant costs: €35,000
• Total loss: €280,000

A proper structure would have cost €35,000 per year, but saved €150,000 per year. The entrepreneur wanted to save €27,000 – and lost €280,000.

My appeal: Invest in quality. Don’t save in the wrong place.

Your next step to a legally secure international structure

Let me be frank in conclusion: CFC-rules don’t make international tax planning impossible. They just make it more demanding.

If you’re willing to invest in real substance and professional compliance, you can realize considerable tax benefits even under German tax residency. The days of quick mailbox tricks are over. But the days of smart, legally secure structures have just begun.

Your three options for the next step

Option 1: Keep the status quo

• You continue paying up to 47% tax in Germany
• No risks, but also no optimization
• Less competitive in the long run

Option 2: Do-it-yourself approach

• You try to do everything yourself
• High error risk
• Often more expensive than professional support

Option 3: Professional structure development

• Systematic analysis of your situation
• Tailor-made, legally secure solution
• Ongoing compliance support

Which option do you choose?

The key takeaways from this article

1. CFC-rules can be overcome: With real substance and business reasoning, Cyprus-structures also work for German tax residents.
2. Substance is crucial: Invest from the start in real business activity on site. Mailbox companies are dead.
3. EU law protects you: As an EU member, Cyprus has rights others don’t. Use them.
4. Compliance is vital: The best structure is worthless without proper documentation and ongoing compliance.
5. Complexity must pay off: Start simple and grow into complexity.
6. Observe transfer pricing: Inter-company prices must be at arm’s length. Do not ignore this.
7. Consider exit strategies: Plan from the outset how to adjust or dissolve the structure later.

My personal advice for you

International tax planning is not a sprint but a marathon. Those who rely on quick tricks will lose in the long run. But anyone ready to invest in substance and compliance can achieve significant benefits even in times of tightening rules.

Cyprus remains one of the most attractive EU tax locations. But only for those prepared to understand and implement the rules professionally.

The real question isn’t whether you should engage in international tax planning – it’s whether you’re doing it right.

I hope this article has helped you ask the right questions and find the right answers.

Yours, RMS

Frequently asked questions about Cyprus CFC-rules

Do CFC-rules also apply to EU-companies like Cyprus?

Yes, German CFC-rules generally also apply to EU-companies. However, EU-companies have special protection under the right of establishment. If you can prove that your Cypriot company does not serve only for tax avoidance but has genuine economic reasons, CFC-rules are often not applicable.

How much substance do I really need in Cyprus?

There are no fixed minimum requirements, but as a rule of thumb: You need a local managing director with real authority, your own office and demonstrable business activities on site. The higher your profits, the more substance you should build. For €500,000 profit, you should have at least 2-3 local employees.

What happens if the tax office applies CFC-rules?

The tax office adds your Cyprus-company’s profits to your German income. You then pay German income tax (up to 47%) after deduction of taxes paid in Cyprus. Additionally, interest and penalties may apply. A later correction can be very expensive.

Can I avoid CFC-rules with the 10% test?

Yes, if passive income makes up less than 10% of gross receipts, CFC-rules do not apply. But you have to plan accordingly from the start – later adjustments are difficult. Important: Active operations must be real, not just for show.

Is a Cyprus-structure worthwhile despite CFC-rules?

Yes, definitely if properly implemented. But you need real substance and professional guidance. As a rule: From €200,000 annual profit, a simple Cyprus-structure can be worthwhile. At higher profits, more complex structures also make economic sense.

How do I properly document business activity in Cyprus?

Keep a detailed “substance diary”: Document all meetings, business decisions and activities in Cyprus. Collect proof of local employees, premises and business relationships. This documentation is worth gold in a tax audit.

What costs arise for a legally compliant Cyprus-structure?

Setup costs: €15,000-35,000 depending on complexity. Ongoing costs: €15,000-40,000 per year for substance, compliance and advice. Sounds like a lot, but with €500,000 profit you still save over €100,000 per year in taxes.

Can I move my existing German GmbH to Cyprus?

Theoretically yes, but in practice very cumbersome and risky from a tax point of view. Usually its better to create a new Cyprus company and gradually transfer functions. This way you can organically build up substance and better control CFC risks.

How do I optimally combine Cyprus with other locations?

Cyprus works excellently as an EU holding in combination with operating companies in Dubai, Malta or Ireland. Each location should have real functions. But beware: Complex structures only pay off for higher profits and require professional support.

What are the biggest risks with Cyprus-structures?

The biggest risks: lack of substance, non-arm’s-length transfer prices, poor compliance and exaggerated complexity. Prevent these errors through professional planning and ongoing management. A well-structured setup is much cheaper in the long run than corrections after a tax audit.