Management and Control Test

In order to ensure tax residency in Cyprus and obtain double taxation treaty protection
Cyprus tax law requires management and control to take place in Cyprus.
However Management and control is not defined
there is no requirement for the majority of directors be resident in Cyprus
However in the case where a company has adopted standard Articles of Association, whereby the affairs of the company are managed by the board of directors, it is accepted that the test is satisfied if the majority of the board of directors are tax residents of Cyprus and board meetings take place in Cyprus.