Based on the Cyprus IP BOX regime, a Company is allowed to deduction of 80% of tax, after all expenses that are suffered wholly and exclusively for the purpose of trade are deducted resulting in the effective tax rate of less than 2.5% of the company’s revenue.
In addition, as Cyprus has no Transfer Pricing rules, the transferor may choose to transfer the intangible asset at any value that benefits his / her personal tax strategy.
Please note that due to OECD Nexus approach, entrance to the Cyprus IP BOX regime (and to any other similar regimes worldwide) has to be done on or before June 2016, as failure to do so according to the deadline will result in restriction of participation. In case someone is registered for Cyprus IP BOX regime before the deadline, that will result in the regime being applicable until June 2021.
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