course content
22/05/2025: 09:00 a.m. - 12:30 a.m.
Module 1: The Cyprus IP Box Regime – Framework and Compliance Issues
1.1. Overview of the Cyprus IP Box Regime introduced in 2016:
▪ Qualifying IP, eligible income, effective tax rate under the nexus-compliant regime.
1.2. Definition of qualifying assets and income:
▪ Alignment with OECD BEPS Action 5.
▪ Exclusion of trademarks and marketing-related IP.
▪ Computation of the nexus fraction.
1.3. Treatment of R&D expenses:
▪ Direct connection between eligible expenditures and qualifying income.
▪ Importance of Cyprus-incurred R&D for preferential treatment.
1.4. Interaction with capital allowances:
▪ Depreciation of IP assets for tax purposes.
▪ Treatment of capitalised development costs.
1.5. Anti-abuse considerations:
▪ Use of the IP regime in substance-based structures.
▪ Restrictions against artificial arrangements or offshoring of ownership.
1.6. EU law implications:
▪ Compatibility with EU State aid rules and principles of free movement.
▪ Review of relevant European Commission and ECJ jurisprudence.
Module 2: Tax Treatment of Royalties and Structuring Through Cyprus
2.1. Cross-border royalty payments:
▪ Absence of withholding tax on outbound royalties when IP is used outside Cyprus.
▪ Exceptions and recent blacklist provisions.
2.2. EU Interest and Royalties Directive:
▪ Implementation in Cyprus.
▪ Anti-abuse rule for claiming benefits.
2.3. Treaty protection for royalty income:
▪ Analysis of typical treaty provisions (Article 12 OECD MTC).
▪ Limitation on source taxation.
▪ Beneficial ownership requirements.
2.4. Inbound royalties to Cyprus:
▪ Taxation under domestic rules depending on source and treaty relief.
▪ Role of substance and transfer pricing.
2.5. Use of Cyprus IP structures in global value chains:
▪ Practical examples of IP ownership, licensing, and cost-sharing through Cyprus.
Legal professionals
Audit professionals
Accounting professionals
Trustees
Protectors (Protectorship services)
