Management and control
Board meetings convened and held in Cyprus, minuted with the reasoning and not only the outcome, by directors who can explain the business without a script. We provide directors on that basis or not at all.
Structures we administer
The Cyprus holding company.
Every other page on this subject will tell you about the tax treatment. That advice is worth having, and it is not ours to give. What we can tell you is the part that decides whether the advice survives contact with a bank, an auditor or a buyer’s counsel: how the company is actually governed, and whether the file says so.
In short
A Cyprus holding company is an ordinary company incorporated under the Companies Law, Cap. 113, used to hold shares in subsidiaries or other assets. Its value depends on it being genuinely managed and controlled in Cyprus — board meetings held here, directors who decide rather than sign, and statutory records that agree with the Registrar. The tax analysis is performed by a licensed tax adviser; the corporate substance that analysis assumes is what an administrator provides.
Statutory position checked . Reviewed at each Cyprus budget and on any amendment to the laws cited on this page.
The part that gets tested
A holding structure is not challenged on its tax opinion. It is challenged on its file.
When a Cyprus holding company runs into trouble, the trigger is almost never the structuring advice. It is a bank refreshing its file and finding registers that do not match the Registrar. It is a group auditor asking for board minutes that were never written. It is a tax authority applying a management-and-control test to a company whose directors cannot describe the business.
The advice was sound. The administration was not, and the two are indistinguishable from the outside — because the only evidence anyone can inspect is the file.
Records that reconcile
Statutory registers reconciled against the Registrar of Companies annually, annual returns (HE32) filed on time, UBO register kept current. Reconciliation is routine here, not a scramble before a transaction.
Substance that matches
Where a structure needs demonstrable presence, we introduce office, payroll and hiring providers and document the footprint. Residency claimed on paper and contradicted by reality is worse than no claim at all.
Legal basis
- Companies Law, Cap. 113
- L.196(I)/2012, Art. 4
- L.188(I)/2007 (UBO)
Formation, directors, secretary, registers and filings are performed by LEVION under its own licence.
One thing worth knowing
The 2026 reform changed the headline rate.
Cyprus corporate income tax rose from 12.5% to 15% with effect from 1 January 2026, under the reform gazetted on 31 December 2025. A great many pages describing Cyprus holding companies still quote the old rate, which is a reasonable way to judge how recently their author looked.
We state it because it is a checkable public fact and a stale figure is a real hazard — not as advice. What the reform means for a particular structure, and whether Cyprus remains the right jurisdiction for it, is a question for a licensed tax adviser.
Statutory position checked . Reviewed at each Cyprus budget and on any amendment to the laws cited on this page.
Where tax comes in
Structuring advice is introduced, not performed.
Tax opinions, advance rulings from the Cyprus Tax Department, transfer-pricing documentation and cross-border coordination come from independent licensed advisers whom we select, brief and coordinate — and for groups, we align them with your existing tax function so the position taken here matches the position taken at home. How introductions work.
Common questions
Cyprus holding companies, answered.
What makes a Cyprus holding company work?
Two things, and only one of them is the tax analysis. The other is whether the entity can show that it is genuinely managed and controlled in Cyprus — board meetings held here, directors who decide rather than sign, records that agree with the Registrar. A holding structure that is well advised and badly administered fails at the first bank review or diligence exercise.
Does LEVION advise on the tax treatment of a holding structure?
No. Tax opinions, advance rulings from the Cyprus Tax Department and transfer-pricing documentation are performed by independent licensed tax advisers, whom we introduce and coordinate. Our part is the corporate substance the opinion rests on, and implementing the adviser’s recommendations in the entity’s records.
What is management and control, in practice?
It is where the company’s strategic decisions are actually made. Documented in practice it means: board meetings convened and held in Cyprus, minutes recording the reasoning rather than only the outcome, directors who can explain the business without a script, and a filing history consistent with all of it. We build and keep that file as a matter of routine, because it is only useful if it exists before anyone asks for it.
What substance does a Cyprus holding company need?
Enough that reality matches what the tax opinion assumes — which varies with the structure and is a question for the adviser, not the administrator. Where a structure needs demonstrable presence, we introduce office, payroll and hiring providers and document the footprint in the corporate file. Tax residency claimed on paper and contradicted by reality is worse than no claim at all.
Bring the structure as it stands.
Whether it is being built or has been running for years and is about to be looked at, we will tell you what we would do differently — specifically.
Related: Cyprus company formation · Cyprus International Trusts · Request a quote