Structures we administer · L.69(I)/1992
The Cyprus International Trust.
One of the strongest succession and asset-protection instruments available inside an EU jurisdiction — and one that is only ever as strong as its administration. A trust whose minutes are missing, whose distributions are undocumented, or whose trustee cannot show independent decision-making is an invitation to the very challenge it was created to resist.
In short
A Cyprus International Trust is a trust governed by the International Trusts Law, L.69(I)/1992 as amended in 2012. It requires that the settlor was not Cyprus tax resident in the calendar year before the trust was created, that the beneficiaries were likewise not Cyprus tax resident in that year (charitable trusts excepted), and that at least one trustee is a permanent resident of Cyprus throughout the life of the trust. Trusts created after the 2012 amendment may exist in perpetuity.
Statutory position checked . Reviewed at each Cyprus budget and on any amendment to the laws cited on this page.
The statutory conditions
Three conditions — and how long the trust may last.
The settlor
Tested at creation
Not a Cyprus tax resident in the calendar year immediately preceding the year the trust was created. The 2012 amendment made clear that the settlor may take up residence in Cyprus at any time afterwards without affecting the trust’s status.
The beneficiaries
Tested at creation
Likewise not Cyprus tax resident in the calendar year preceding creation — with charitable trusts excepted, whose beneficiaries may be Cyprus residents at any time. Beneficiaries too may move to Cyprus after the trust exists.
The trustee
Tested continuously
At least one trustee must be a permanent resident of Cyprus for the whole duration of the trust — not merely at the moment of creation. This is the condition that fails quietly, years later, and the reason structures of any permanence appoint a corporate trustee rather than an individual.
Duration
No statutory limit
A Cyprus International Trust created after the 2012 amendment may exist in perpetuity, subject to the terms of the trust instrument itself.
Legal basis
- L.69(I)/1992 as amended
- L.196(I)/2012, Art. 4(1)(b)
Acting as corporate trustee and fiduciary administrator is licensed activity performed by LEVION.
Why a corporate trustee
An individual trustee is a single point of failure with a lifespan.
The Cyprus-resident trustee requirement runs for the whole life of the trust. If the only resident trustee retires, emigrates or dies, a condition of the trust’s status lapses — often without anyone noticing until the structure is examined for some entirely unrelated reason.
A corporate trustee has no such failure mode. It also brings the thing individual trustees most often lack: a documentary habit. Trustee decisions are minuted as decisions, with the reasons recorded rather than only the outcome. Beneficiary records, letters of wishes and distribution files are maintained to the standard a court, a foreign tax authority or a successor trustee would expect to inherit.
- Corporate trustee and fiduciary administrator appointments
- Administration strictly in accordance with the trust deed and applicable law
- Beneficiary and fiduciary records; trust-register notifications where required
- Distribution documentation, trustee minutes and annual trustee reviews
- Coordination with the settlor’s own counsel and tax advisers in each relevant jurisdiction
Where tax and law come in
We administer the trust. We do not advise on it.
Drafting the trust instrument, and the tax treatment of the trust, its settlor and its beneficiaries in every jurisdiction they touch, are for practising advocates and licensed tax advisers — whom we introduce and coordinate with the settlor’s own counsel. How introductions work.
Common questions
Cyprus International Trusts, answered.
What is a Cyprus International Trust?
A trust governed by the International Trusts Law, L.69(I)/1992 as amended in 2012. It requires that the settlor was not Cyprus tax resident in the calendar year before the trust was created, that the beneficiaries were likewise not Cyprus tax resident in that year (charitable trusts excepted), and that at least one trustee is a permanent resident of Cyprus throughout the life of the trust.
Can the settlor or beneficiaries move to Cyprus afterwards?
Yes. The residency conditions are tested by reference to the calendar year preceding creation. The 2012 amendment made clear that the settlor and the beneficiaries may take up residence in Cyprus at any time after the trust is established without affecting its status.
How long can a Cyprus International Trust last?
A Cyprus International Trust created after the 2012 amendment may exist in perpetuity, subject to the terms of the trust instrument itself. There is no statutory limit on its duration.
Why does the Cyprus-resident trustee requirement matter?
Because it is a condition of the trust’s status for the whole of its life, not just at creation. If the only Cyprus-resident trustee retires, dies or moves, the trust has a problem. A corporate trustee does not have that failure mode, which is one reason structures of any permanence use one — and it is a licensed activity under Article 4, L.196(I)/2012.
Does LEVION advise on trust taxation?
No. The tax treatment of a trust, its settlor and its beneficiaries — in Cyprus and in every jurisdiction they touch — is for licensed tax advisers, whom we introduce and coordinate with the settlor’s own counsel. We act as corporate trustee and fiduciary administrator: the deed is administered as written, decisions are minuted with reasons, and the file is kept to the standard a successor trustee would expect to inherit.
Discuss a trustee appointment.
Whether the trust is being established or an existing one needs a trustee that will still be there in thirty years.
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