ΠΕΡΙΓΡΑΦΗ

This specialised course provides a clear, practice-oriented overview of how income and gains from immovable property are taxed under Cyprus law, tax treaties, and EU rules. It covers the treatment of capital gains from real estate and shares in property-rich companies, rental income taxation for both individuals and legal persons, and the effect of recent legislative changes introducing withholding tax on outbound payments.

Participants will explore the allocation of taxing rights under tax treaties, especially Articles 6 and 13 of the OECD and UN Models, and understand how anti-abuse measures—such as GAAR, LOB clauses, and substance requirements impact non-resident property owners. The course is ideal for professionals dealing with real estate transactions, structuring, and cross-border property holdings involving Cyprus.

Why Sign Up for This Course?

Cyprus continues to attract foreign investment in real estate but the tax implications are more complex than ever. Withholding tax, capital gains tax, and treaty interpretation issues can expose clients to unnecessary costs or disputes if not properly managed.

This course helps you:

• Understand how Cyprus taxes immovable property and what recent changes mean for clients.
• Navigate capital gains rules on shares in property-rich companies.
• Apply treaty provisions on property income and cross-border gains.
• Anticipate risks from anti-abuse clauses, substance failures, and LOB/treaty denial rules.

Whether you are advising on acquisitions, holding structures, or disposals, this course gives you the clarity and technical confidence to do it right.

ΣΕ ΠΟΙΟΥΣ ΑΠΕΥΘΥΝΕΤΑΙ

suitable for

• 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

ΠΕΡΙΣΣΟΤΕΡΕΣ ΠΛΗΡΟΦΟΡΙΕΣ

Course content

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.