We are a dedicated team of experienced lawyers committed to protecting your rights and delivering justice. With years of expertise in diverse
areas of law, we provide trusted legal solutions for individuals, families, and businesses
We design international business structures through Cyprus that hold up under EU directives, satisfy substance requirements, and actually reduce what your group pays across jurisdictions, not just on paper.
Applied the moment a structure can't prove genuine substance.
When entities across jurisdictions weren't structured to work together.
Retroactively, once a tax authority tests management and control.
A structure built to survive scrutiny costs a fraction of unwinding one that couldn’t.
THE REAL PROBLEM
Why International Structures Through Cyprus Go Wrong
The structure exists only on paper.
A Cyprus holding company with no local board activity and no economic substance is exactly what tax authorities elsewhere are trained to challenge. If management and control can’t be demonstrated, the tax residency on which the whole structure depends is at risk.
Treaty access was assumed, not confirmed.
Cyprus holds one of the widest double tax treaty networks in Europe, but relief isn’t automatic. Each treaty has its own tests, increasingly including beneficial ownership and substance requirements, that the structure has to actually satisfy first.
The EU directives weren’t built in from the start.
The EU Parent-Subsidiary Directive can eliminate withholding tax on dividends between EU group companies, and the Interest and Royalties Directive does the same for cross-border interest and royalties. Structures set up without these in mind often pay withholding tax that a properly sequenced structure would have avoided.
Only one jurisdiction’s rules were considered.
A structure that appears efficient from Cyprus alone can still trigger anti-avoidance or CFC rules or result in the loss of treaty benefits in the other jurisdictions involved.
IN PLAIN TERMS
What an “International Business Structure” Actually Is
IN PLAIN TERMS
A holding company, its subsidiaries and an IP entity each need a jurisdiction and a reason, not just convenience.
Dividends, interest and royalties each have their own treaty and directive treatment.
Genuine management, real board decisions made in Cyprus, documented substance.
What an “International Business Structure” Actually Is
Where income originates, where it needs to land, before any entity is formed.
Holding, financing, or IP structure, whichever role fits your group's actual activity.
Real board meetings and documented decisions are held in Cyprus.
Structured so Parent-Subsidiary and Interest and Royalties relief applies where you qualify.
Tested against the specific treaty involved, not Cyprus's network in general.
Working alongside counsel wherever your group operates.
Why Businesses Trust Naklaw to Structure Internationally
NOT SURE WHICH SERVICE YOU NEED?
What’s Your Situation?
We map your group and design a Cyprus structure sized to your actual cross-border activity.
CTA → Design Your Group StructureWe assess where the structure falls short and rebuild the substance and documentation it needs.
CTA → Request a Substance ReviewWe design the holding layer and align it with Cyprus's tax treatment, where your assets genuinely qualify.
CTA → Structure Your Holding CompanyWe assess your group's actual activity first and tell you honestly whether Cyprus is the right jurisdiction.
CTA → Book a Structuring ConsultationFAQS
International Business Structures, Frequently Asked Questions
The arrangement of holding companies, subsidiaries, and financing or IP entities across jurisdictions determines how a group's income, ownership, and tax obligations flow.
EU membership, one of Europe's widest double tax treaty networks, and access to the EU Parent-Subsidiary and Interest and Royalties Directives.
Genuine management and decision-making are actually happening in Cyprus. Without it, tax authorities can deny the residency and treaty benefits on which the structure depends.
No, specific ownership thresholds and holding periods apply. We confirm your group qualifies before relying on either directive.
Not necessarily. Substance expectations and anti-avoidance rules have tightened across the EU. Older structures often need a review.
Typically, four to eight weeks from mapping to full implementation, depending on the entities and jurisdictions involved.
Yes. An international structure only works if it holds up in every jurisdiction it touches, so we coordinate directly with counsel in each jurisdiction where your group operates.
Yes, a substance and treaty-access review is often the first step when a structure was built elsewhere and never stress-tested.
An international structure that only works on a slide deck isn't a structure; it's exposure waiting for an audit. Let's build one with real substance, confirmed treaty access, and a Cyprus position your group can actually rely on.
BOOK YOUR STRUCTURING CONSULTATION+357 25-352-352 · info@naklaw.com · Limassol, Cyprus
We are a dedicated team of experienced lawyers committed to protecting your rights and delivering justice. With years of expertise in diverse areas of law, we provide trusted legal solutions for individuals, families, and businesses.We are a dedicated team of experienced lawyers committed to protecting your rights and delivering justice. With years of expertise in diverse areas of law, we provide trusted legal solutions for individuals, families, and businesses.We are a dedicated team of experienced lawyers committed to protecting your rights and delivering justice. With years of expertise in diverse areas of law, we provide trusted legal solutions for individuals, families, and businesses.
Following the accession of Cyprus in the EU in 2004 and the abolition of the "offshore regime", Cyprus has maintained a simplified and effective tax system in full compliance with the EU and the OECD.
As a result of the above Cyprus has become a stable EU, "non-offshore" low tax jurisdiction with a beneficial tax regime for foreign businesses and individuals as well as a safe professional business environment.
Cyprus has one of the lowest-taxation rates within the EU, with a flat tax rate at 15% on profit. Cyprus offers additionally to its tax benefits, great advantages as a respectful and useful jurisdiction for holding companies.
It is important to indicate that the business climate in Cyprus is based on a free and open economy, offering first-class legal and financial expertise. It's very easy to fly in and out of Cyprus throughout the year.
When I faced unfair treatment at work, this incredible team stood by my side, fought tirelessly for my rights, and ensured that I finally received the justice I truly deserved
We take pride in delivering justice with integrity, dedication, and trusted legal expertise. Our clients’ voices reflect the true strength of our firm
We work with individuals, families, startups, and large corporations across various legal matters.
Yes, we provide a free 30-minute consultation to understand your case before moving forward.
Our fees are transparent and flexible — you can choose between hourly rates, flat fees, or monthly packages.
Yes, our team also assists with immigration & international legal matters.
You can easily schedule an appointment through our website or by contacting our office directly.
Our personalized approach, proven track record, and dedicated team of attorneys set us apart.
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+357 25-352-352
info@naklaw.com
Anexartisias & Athinon, Nora Court, 2nd Floor, Office 201-202, 3040 Limassol, Cyprus
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