Cyprus Fact-File Part 2:
Individual Business Domestic Taxation
2.2 Cyprus Permanent Establishment
The definition of a permanent establishment
in Cyprus is a business that is wholly or partly carried on
in the country at a fixed address. This includes locations
that are management offices, branches, factories, workshops
or building sites where construction projects have lasted
more than three months. Any profits made by a permanent establishment
in Cyprus are subject to tax there, even where the individual
or entity is owned by a non-resident for tax purposes. Permanent
establishments located outside of Cyprus but held by a Cypriot
tax resident can be exempt from tax, although if more than
50% of the income of the permanent establishment emanates
from investment income and the tax rates in the country in
which the establishment is situated are lower than those in
Cyprus, then there will be liability to pay Cypriot tax.
|