course content
26/06/2025: 09:00 a.m. - 12:30 a.m.
1. Definition and scope of immovable property
▪ Interpretation under Cyprus domestic law.
▪ OECD and UN Model definitions in tax treaties.
2. Capital Gains Tax (CGT) regime
▪ Application of CGT on disposals of Cyprus-situated immovable property.
▪ CGT on shares in companies deriving their value from such property.
3. Taxation of rental income
▪ Differences between individual and corporate landlords.
▪ Applicable rates, exemptions, and available deductions/allowances.
4. Withholding tax on rent or sale proceeds
▪ 2023 legislative changes introducing WHT on certain outbound payments.
▪ Practical impact and obligations for remitters.
5. Treaty allocation of taxing rights
▪ Article 6 and Article 13 OECD/UN Model provisions.
▪ When Cyprus can and cannot tax income/gains from real estate.
6. Anti-abuse and economic substance
▪ Substance requirements for non-resident owners.
▪ Risk areas: GAAR, limitation-on-benefits (LOB) clauses, and treaty denial provisions.
Real estate and tax lawyers
Accountants and tax advisors
Property investment managers
Corporate service providers
Developers and property funds with Cyprus structures
In-house finance/legal teams managing real estate portfolios