Καταπιστεύματα στην Κύπρο

The Cyprus International Trust framework

The Cyprus International Trusts Law (69(I)/1992), significantly amended in 2012 and subsequent years, established one of the most flexible trust regimes globally. A CIT can be created by a settlor who is not a Cyprus resident in the year preceding creation. Beneficiaries can be Cyprus residents or non-residents. At least one trustee must be Cyprus resident during the trust's existence.

CITs may hold worldwide assets (real estate, securities, business interests, intellectual property, cash, art) and can be structured for various purposes including family wealth preservation, succession planning, employee benefit schemes, philanthropic activities, and asset protection.

Key advantages

Perpetual duration: unlike common law trusts limited to 21 years, CITs can continue indefinitely, ideal for multi-generational wealth structures. Asset protection: assets settled into a CIT enjoy protection against subsequent claims by settlor's creditors, subject to a 2-year fraud lookback period. Tax neutrality: CITs are not taxed in Cyprus on foreign-source income or gains where beneficiaries are non-Cyprus residents. Confidentiality: trust deed and beneficiary information are not publicly filed, though UBO disclosure to competent authorities applies. Flexibility: settlor can reserve powers (investment direction, beneficiary appointment) without invalidating the trust.

Setting up a CIT

Establishing a CIT involves selection of trustee (Cyprus-licensed trust company), drafting the trust deed specifying beneficiaries and terms, transferring assets to trust ownership, and ongoing administration by the trustee (typically annual accounts, tax filings for Cyprus-source income, distribution management). Typical setup costs range €3,000-€10,000 for standard CIT structures, higher for complex arrangements.

Annual trustee and administration fees depend on trust complexity and asset value, typically €5,000-€20,000+ annually for actively managed CITs.

CITs and international tax planning

CITs are commonly integrated with Cyprus holding companies, foundations, and other structures to achieve tax-efficient wealth structuring. Post-BEPS, the emphasis is on genuine substance — real Cyprus trustee activity, documented trustee decision-making, and commercial rationale beyond tax optimisation. CITs cannot serve as passive tax-avoidance vehicles under modern rules.

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