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Updates by Registrar regarding the BO register

Updates to the Beneficial Owners register

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The Department of the Registrar of Companies and Intellectual Property made the following announcement on the 28th of February 2024 based on the Beneficial Owner register:

1. All companies established or registered under the Companies Law, Cap. 113, all European Public Limited Liability Companies (SE) and all Partnerships (hereinafter Organizations) or their officers/partners are invited to access the Register of Beneficial owners until March 31, 2024 and to update it, either with details of Beneficial Owners, or by declaring their exclusion based on paragraph 3 (1)(a)(b) of Directive KDP112/2021 as it was modified, or by exercising the right of Due Diligence. From the 1st of April, monetary charges and other sanctions will be imposed for non-compliance.

2. From 1 April 2024 all the actions below will be available, and failure to comply with them will result in financial charges:

  • The Register of Beneficial Owners should be updated within 45 days from the day on which the Organization or its officers/partners became aware of the change of Beneficial Owners
  • The Register of Beneficial Owners should be informed within 90 days from the establishment of a new Organization, by the Organization itself or its officers/partners with regards to the Beneficial Owners’ details
  • From 01/10 until 31/12 of each year, the Organizations or their officers/partners should confirm the information included in the Register of Beneficial Owners
  • Within 30 days of receiving an electronic notification about data mismatch, the Organisation or its officers/partners should take necessary actions and correct such data

3. It is reminded that the following actions are still valid:

  • Online research in the records of the Register of Beneficial Owners
  • Request for exemption from disclosure of information
  • Request for access to the details of a minor

Do not hesitate to contact our team for providing you further explanation and assistance with respect to the Register of Beneficial Owners

Original source by the Department of Registrar of Companies and Intellectual Property

Stricter rules by Council and Parliament regarding Anti-Money Laundering (AML)

AML: Stricter rules by Council and Parliament

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The Council and Parliament of the EU provisionally agreed upon upgrading several parts of the anti-money laundering package, aiming to protect EU citizens and the EU’s financial system against money laundering and terrorist financing.

Under the new agreement, the rules applicable to the private sector will be transferred to a new regulation, while the organization of AML/CFT combat systems at Member State level will be regulated by a relevant directive.

The provisional agreement on an anti-money laundering regulation will, for the first time, exhaustively harmonise rules throughout the EU.


The updates of the AML package are separated in two main pillars as follows:

1. Anti-money laundering regulation

A. Obliged entities: The list of obliged entities has been expanded to include new bodies which are the crypto-asset service providers (CASPs), traders of luxury goods and professional football clubs and agents. The due diligence and reporting obligations vary depending on the type of entity. Also, obliged entities will need to apply enhanced due diligence measures to occasional transactions and business relationships involving high-risk third countries which could be a threat to the integrity of the EU’s internal market.
B. Enhanced due diligence: Specific enhanced due diligence measures will apply to cross-border correspondent relationships for crypto-asset service providers, while credit and financial institutions will follow more specific and strengthened due diligence measures when assessing high net-worth individuals with large amounts of assets.
C. Cash payments: The EU-wide maximum limit for cash payments is set to €10.000 while member states may use their discretion to impose a lower maximum limit. Moreover, obliged entities should identify and verify the identity of an individual carrying out an occasional transaction in cash between €3.000-€10.000.
D. Beneficial ownership: The rules on beneficial ownership and multi-layered ownership and control structures are clarified, beneficial ownership is based on two components – ownership and control. The beneficial ownership threshold is set at 25% and applies to both EU entities and non-EU entities doing business or buying property in the EU. Registration of the beneficial ownership of all foreign entities that own real estate with retroactivity until 1 January 2014.
E. High-risk third countries: Enhanced due diligence measures will be required for the occasional transactions and business relationships involving high-risk third countries.

2. The 6th Anti-money laundering directive

A. Beneficial ownership registers: The information submitted to the central register should be verified, while sanctioned entities or individuals should be flagged. The entities in charge of the registers are authorized to inspect the premises of the registered legal entities if deemed necessary, while persons of the public with legitimate interest, including press and civil society, may also access the registers. In addition, real estate registers should be accessible to competent authorities through a single access point, to facilitate investigations of criminal cases.
B. Financial intelligence unit (FIU) responsibilities: The FIU of each member state will have immediate and direct access to financial, administrative and law enforcement information and will continue to share information to competent authorities while ensuring that fundamental rights are taken into consideration. Furthermore, the agreement sets out the context in which FIUs will be able to suspend or withhold consent for a transaction under investigation.
C. Supervision: All obliged entities are subject to adequate and effective supervision and suspicious behaviour will be reported to the member state’s FIU. In addition, new supervisory measures will apply to the non-financial sector, by the so-called supervisory colleges, and the new Anti-Money Laundering Authority (AMLA) will prepare draft regulatory technical standards.
D. Risk assessment: The Commission will carry out an EU level evaluation and provide recommendation to member states with regards to the risk assessment they carry out, aiming to effectively mitigate any money laundering and terrorist financing risks.

The legislative proposals are pending approval before being formally adopted and entered into force by the Council and the Parliament. This provisional agreement will carefully align EU rules, minimize possible risks of unlawful activities in the financial system, and strengthen the national AML systems for combating fraudulent and illegal proceeds.

Official source here

EU Blue Card Visa scheme legislation approved in Cyprus

Attracting foreign talent with EU Blue Card Visa

Posted on | by [email protected]

On Wednesday 17th of January, the Council of Ministers approved the amendment of the legislation for the implementation of the European Blue Card scheme in Cyprus. This Card serves as a permanent residence and EU citizenship to non-EU/EEA nationals while providing comprehensive socio-economic rights.

The proposed legislation harmonizes with the relevant EU directive with regards to the entry and residence permit of highly skilled non-EU nationals to be employed in member states, and aligns with the 2021 talent attraction program, in an effort to promote legal migration.
The aim of this initiative is to encourage foreign qualified workers to live and work in Cyprus within a friendly framework and benefit from flexible entry requirements, increased rights and opportunities, as well as streamlined mobility.


To qualify as high-skilled, individuals must either possess a higher education qualification from a course lasting at least three years, or have at least three years of professional experience in the Information and Communication Technology sectors within the past seven years.
The adoption of this scheme not only fosters diversity and increases the competencies of the local labour market, but it also shapes the future of the island as an international and growing business center.

How can we help you
Cyprus offers more business and lifestyle opportunities and digital developments than ever before. If you are searching for a better way of life and consider living and working in Cyprus, our team of experts can advise and support you throughout your relocation journey.

Contact us here.

Extension to submission of UBO data to Cyprus Registrar by 31 March 2024

Submission of Beneficial Owner Registry data: extension until 31 March 2024

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On 17 January 2024, the Department of Registrar of Companies and Intellectual Property announced that with the aim to optimally update the Register of Beneficial Owners on the basis of the implementation of the upgraded platform, an extension has been granted for the submission of data for all Companies and other Legal Entities until 31 March 2024.

It has been noted that after the specified date, non-compliant Companies and other Legal Entities will be subject to a financial burden based on Article 188(I)/2007 (Prevention of Combating Money Laundering, a law passed by the House of Representatives on 23 February 2021).

Original Source

IDLAW and Nobel Trust Tax event, 30th November 2023, Nicosia, Cyprus

Recent Developments in EU Tax Law, Taxpayers’ Rights and the Impact on Cyprus

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IOANNIDES DEMETRIOU LLC and Nobel Trust Ltd jointly organised the event titled: “Recent Developments in EU Tax Law, Taxpayers’ Rights and the Impact on Cyprus” on Thursday, 30th November 2023, Nicosia, Cyprus.

The above topics were presented by leading counsel Professor Philip Baker, KC, OBE, Field Court Tax Chambers & the University of Oxford, and Ioannides Demetriou LLC’s collaborating Special Tax Counsel Professor Christiana HJI Panayi, Chair in Tax Law at Queen Mary University of London.

The presentations provided a unique opportunity to be informed of the recent legal developments in relation to the protection of taxpayers’ rights as well as anticipated developments in tax law within the EU.

Recording of the event:

Cyprus Naturalisation: updated and more flexible rules

Cyprus naturalisation – updated and more flexible rules

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On the 30th November 2023, the Cypriot House of Representatives approved an amendment of the Civil Registry Law, relaxing the rules for granting Cypriot citizenship to foreign nationals and modernising the current legal framework. The aim is to attract and encourage highly skilled tech professionals and their families to stay in Cyprus. The bill is subject to government approval before it comes into force.

This initiative enhances the country’s reputation as a continuously developed international business hub and is expected to foster innovation, cultivate domestic talent and fuel economic growth.

The amendments relate mainly to the amount of time that foreign nationals are expected to reside in Cyprus before applying for naturalization, as well as their knowledge of the Greek language. There are also special provisions which apply to individuals with high qualifications and skills in the technology sector.

Applicants must meet the following main criteria:

• Legal and continuous physical stay in Cyprus for the twelve months preceding the application for naturalisation (periods of absence should not exceed 90 days in total).
• Legal physical stay in Cyprus for at least seven out of ten years preceding the aforesaid 12-month period (periods of absence should not exceed 90 days in total, per year).
• To be of good character and have a clean criminal record.
• To be financially self-sustained and have a suitable place of residence.
• To have sufficient knowledge of the Greek language (certificate of basic knowledge, Level B1) and basic knowledge of the country’s political and social status.
• To have the intention to stay in Cyprus.

Individuals with high skills in the technology sector and working in companies of foreign interest should meet the following special provisions:

• The period of seven years (out of the last ten) of residence in Cyprus is reduced to four years for applicants having a certificate of knowledge of the Greek language of A2 level, and three years if the certificate is of B1 level.
• Family members of the applicants may also apply for naturalisation, under the same conditions. Spouses or civil partners of the applicants should have the same certificates of knowledge of the Greek language as the applicants. Children of the applicants that reach adulthood (18 years of age) during the examination of their parent’s application should still be considered minors for the purpose of the Law and be eligible for naturalisation. Dependent adult children with disabilities are also eligible.

The applications of highly specialised professionals are examined on a ‘fast-track’ basis which does not exceed eight months, upon the payment of a fee. The details of this process and the relevant fee should be determined by way of a Ministerial decision.

It is also noted that applications for citizenship that were submitted before the aforementioned amendments shall be examined under the new criteria as described above.

For any assistance, our experienced team can guide and support you through the naturalization process. Contact us here.

Cyprus ultimate beneficial owners electronic register

Register of Beneficial Owners: Implementation of the final solution of the Electronic System

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The Department of Registrar of Companies and Intellectual Property following its announcement “Notice for registration of details of Beneficial Owners (BOs) in the Register of Beneficial Owners (BO register) and imposition of fines” dated 09/01/2023, has announced the commencement of the application of the final solution of the electronic system of the BO register from November 14, 2023.

The final solution of the electronic system will be implemented in its entirety within 2024 and constitutes of three phases:

Period 1: 14/11/2023 – 31/12/2023

All companies established or registered under the Companies Law, Cap. 113, all European Public Limited Liability Companies and all Partnerships (hereinafter ‘Organizations’) or their officers/partners are invited to enter the system of the final solution and proceed with the updating/re-registering their Beneficial Owners, even if they have already done so in the interim solution system. For re-enrollment purposes, the Beneficial Owners’ data that have already been provided in the interim solution will be shown, in order to see what has been submitted and then re-submit the same. No financial charge will be imposed during the first period. The way to enter the final solution system will be the same as that of the interim solution.

From this period as well as in the following periods, it will be possible to:

  • Exercise due diligence,
  • Obtain an exception to the information disclosure,
  • Request access to the data of minors,
  • Organizations that are listed on a regulated market, which is subject to disclosure requirements under European Union Legislation will be able to declare their exemption,
  • Organizations subject to equivalent international standards that ensure adequate transparency of proprietary information will be able to declare their exemption;
  • The Obliged Entities and the Competent and Supervisory Authorities will be able to carry out an electronic search in the system on their own. Regarding the Obliged Entities, there will be an examination and then acceptance or rejection of their role by Department officials. The online survey of Obliged Entities will be completed by paying the corresponding fee of 3.50 Euros per Organization.

It should be noted that those Organizations which have demonstrated or intended to demonstrate due diligence during the interim solution should do so in the final solution. The same applies to Organizations that will have to declare their exemption from the final solution either because they are listed on a regulated market, which is subject to disclosure requirements under European Union Legislation, or because they are Organizations subject to equivalent international standards that ensure sufficient transparency of ownership information, which should state their exemption  in the final solution.

Period 2: 01/01/2024 – 29/02/2024

Those companies incorporated or registered under the Companies Law, the European Public Limited Liability Companies and Partnerships or their officers/partners, that have not updated/re-registered the data of their Beneficial Owners into the final solution system during Period 1, will be subject to a penalty.

The charge will be applicable from 01/01/2024 until the date of updating/re-registering the Beneficial Owners’ data. After the above Organizations have paid the relevant penalty, they will be able to proceed with registration and/or suspension and/or change without any further penalty that governs the specific actions based on the relevant Directive as amended.

Those companies that have been established or registered under the Companies Law, the European Public Limited Liability Companies and Partnerships or their officers/partners, that have updated/re-registered the Beneficial Owner’s data, will not incur a penalty and will be able to register and/or suspend and/or make changes without any penalty that governs the specific actions based on the aforementioned Directive.

Period 3: from 01/03/2024 onwards

During this period, the following actions will be available:

  • Updating the Register of Beneficial Owners
  • Confirmation of Beneficial Owners
  • Mismatch
  • Electronic search in the Register of Beneficial Owners
  • Request for exemption from disclosure of information
  • Request for access to the data of a minor
  • Calculations of monetary charges where applicable

Our team can provide you with any assistance you might need with regards to the Register of Beneficial Owners. For any clarifications or questions, do not hesitate to contact us.

View original source here.

registration of ultimate beneficial owners Cyprus companies

Registration of beneficial owners data to avoid imposition of fines

Posted on | by [email protected]

The Department of the Registrar of Companies and Intellectual Property, following its announcement on the Functioning of the Register of Beneficial Owners in the interim solution, and in view of the imminent implementation of the final solution of the electronic system of the Register of Beneficial Owners, which is expected around the end of October 2023, invites all companies incorporated or registered under the Companies Law, Chapter 113, the European public limited liability companies (SE) and Cooperatives as well as their officers/partners, if they have not already done so, to register the details of their beneficial owners in the Register of Beneficial Owners of Companies and other legal entities maintained by the Department, in order to avoid the imposition of a monetary burden and/or the initiation of criminal proceedings due to non-compliance. The deadline is on 30th of September 2023.

In addition, following the start of the final solution, a period of one month will be granted for confirmation and completion of the information that has been registered in the system of the interim solution and will have been transferred to the final system by all entities. During this period, requests for information release exemptions should be filed along with reasons for exercising due diligence.

It is pointed out that, at the end of the one-month period, the automatic imposition of fines through the final solution of the electronic system of the Register of Beneficial Owners for the non-compliant companies will begin.

It is reminded that, regardless of the criminal responsibility or prosecution of any person, in case of non-compliance the company or other legal entity and each of its officials are subject to a fine of two hundred euros (€200) and a further fine of one hundred euros (€100) for each day of continued infringement with a maximum total charge of twenty thousand euros (€20,000).

Our firm has extensive expertise on the matter and would be pleased to assist your organization to meet its compliance requirements.

For further inquiries and assistance, please contact us and we will get back to you.

Income tax law amendments, Cyprus, June 2023

Income Tax Law Amendments

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On 22 June 2023, the House of Representatives passed additional amendments to the Income Tax Law with regards to Article 8(23A).

The Article provides a 50% exemption from income tax on the remuneration of individuals employed in Cyprus, subject to certain criteria. The recent amendments are as follows:

• The exemption will be granted if the individual was not a resident of Cyprus for 15 consecutive years prior to any employment in the Republic. Previously, the exemption was applicable if the individual was not a Cyprus resident for 10 consecutive years.
• The exemption will be granted for a period of 17 years from the date of employment regardless of whether the individual changed employer during this period. Previously, the exemption was only granted for the first employment of the individual in Cyprus.

It is important to note that these amendments also apply to the transitional provisions that were formerly introduced in Article 8(23A) in 2022 and that the individuals that were entitled to the 50% income tax exemption based on the old provisions of Article 8(23A), will continue to claim the exemption, provided that they meet all the requirements.