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CYPRUS INTERNATIONAL TRUST
The revamped Cyprus International Trust (CIT), provides for the highest possible degree of asset protection
internationally, extensive tax benefits and strong confidentiality capabilities.
LEGAL FORM
A CIT is a legal arrangement created by the Settlor who transfers property/assets to a legal or physical person, called
the Trustee, who holds the property for the benefit of the beneficiary/ beneficiaries in accordance with the terms of
the “Trust Deed”.
PARTIES TO THE TRUST
Settlor: a person who grants Trust Property to the
Trustee subject to the terms of the Trust deed.
A CIT MUST HAVE
 At least one non Cyprus resident Settlor; AND
 At least one non Cyprus resident
Beneficiary/beneficiaries AND;
 At least one eligible Cyprus Resident Trustee.
Trustee: a person who holds the Trust Property for the
benefit of the Beneficiaries. A Trustee can also be a
Beneficiary.
Beneficiary: a person who has a right or interest in the
Trust Property.
A CIT MAY HAVE
 A protector at the choice of the settlor;
 An investor advisor at the choice of the settlor;
 Management committee at the choice of the
settlor.
CORE BENEFITS OF A CIT
TAX ADVANTAGES
 No Tax on non-Cyprus income and profits of a CIT;
 Beneficiaries may be taxable in their country of residence, only upon actual distributions;
 No capital gains tax on sale of titles;
 No inheritance or wealth taxes applicable;
 Low stamp duty;
 Possible disapplication of CFC Rules.
ASSET PROTECTION
 Cyprus courts have exclusive jurisdiction as to the validity of CIT;
 The provisions of CIT Law have express Superiority of over any other law, or treaty applicable in Cyprus;
 No claim can be filed in relation to the assets of the Trust in the case of bankruptcy or liquidation of the Settlor/
Beneficiary or in cases of institution of legal proceedings against the Settlor/ Beneficiary by his creditors;
 Foreign or local succession laws do not apply - Avoidance of forced heirship rules and certainty of succession:
Any distribution of Trust property shall be made in accordance to the terms of the Trust deed in the event of
death of Settlor or Beneficiary.
FLEXIBILITY
 Possibility to grant extended powers to Settlors;
 Ability on changing the jurisdiction of the Trust;
 No statutory limitations on mode of operation, objects, activities or mode of distribution of the Trust;
 Flexibility on investments and perpetual accumulation of income;
 May be fixed or discretionary.
ADDITIONAL BENEFITS
 High protection-The legal time limit to challenge the Trust is two years;
 Quick to set-up: usually within 2 working days;
 No public registries for Trusts;
 No filing requirements;
 Strict confidentiality: disclosure of any details relating to a CIT is only allowed after a relevant court order.
EXAMPLES OF USAGE OF A TRUST
1st EXAMPLE SUCCESSION 2nd EXAMPLE/ PROTECTION
 A: - Non-resident UBO (‘NR’) of a Cyprus Company
(‘CYCO’) through nominees;
 B: - NR of a CIT, shareholder of a CYCO
 In the event of the death of: -
- A: - law of succession of his country will apply with
regards to who will inherit the shares. Further, the
business of the CYCO may be paused until the new
beneficiary is ascertained
- B:-succession laws do not apply and as such the
Trustees shall manage and continue the business of
the CYCO as per the Trust Deed.
 Family asset protection in the case of divorce or
complicated family issues or bankruptcy etc.
 A couple with children and common business venture
gets divorced.
 The court ordered for the business venture to be
transferred for the benefit of the minors.
 In order to protect the minor and the business venture,
a CIT can be created with beneficiary being the minor.
The mother was the protector and she was also able to
manage and safeguard the business venture.
3rd EXAMPLE/ BUSINESS VEHICLE 4th EXAMPLE BUSINESS VEHICLE
 Usage of a CIT, as a way to safeguard the continuity of
business operations, in the event of settlor or
beneficiary attack by authorities. Specifically, CITs may
cater for the possibility of automatic removal or
disqualification (permanent or temporary) of
beneficiaries, in cases where the beneficiaries are found
guilty of tax related crimes or are under investigation,
or in case such beneficiaries are classified as sanctioned
persons.
 This method enables the CIT to continue its operations
unimpeded and guarantees asset security.
 Family owned and managed business.
 Elderly CEO, children uninterested in managing the
business.
 Transfer of the business assets to the Trustees to be
managed by the current employees as investment
advisors.
 Beneficiaries of the Trust are the family whilst the
employees are additional beneficiaries and obtain
bonus/ pension in accordance with the performance of
the Trust.
OUR SERVICES
 Provision of Trustee, Protector, Advisor;
 Advising, Drafting, Structuring & Management of Trusts;
 Legal representation in Court Proceedings;
 Advising on Tax & Compliance matters.
DISCLAIMER
This publication has been prepared as a general guide and for information purposes only. It is not a substitution for professional advice. One must not
rely on it without receiving independent advice based on the particular facts of his/her own case. No responsibility can be accepted by the authors or the
publishers for any loss occasioned by acting or refraining from acting on the basis of this publication

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Cyprus international Trusts

  • 1. CYPRUS INTERNATIONAL TRUST The revamped Cyprus International Trust (CIT), provides for the highest possible degree of asset protection internationally, extensive tax benefits and strong confidentiality capabilities. LEGAL FORM A CIT is a legal arrangement created by the Settlor who transfers property/assets to a legal or physical person, called the Trustee, who holds the property for the benefit of the beneficiary/ beneficiaries in accordance with the terms of the “Trust Deed”. PARTIES TO THE TRUST Settlor: a person who grants Trust Property to the Trustee subject to the terms of the Trust deed. A CIT MUST HAVE  At least one non Cyprus resident Settlor; AND  At least one non Cyprus resident Beneficiary/beneficiaries AND;  At least one eligible Cyprus Resident Trustee. Trustee: a person who holds the Trust Property for the benefit of the Beneficiaries. A Trustee can also be a Beneficiary. Beneficiary: a person who has a right or interest in the Trust Property. A CIT MAY HAVE  A protector at the choice of the settlor;  An investor advisor at the choice of the settlor;  Management committee at the choice of the settlor. CORE BENEFITS OF A CIT TAX ADVANTAGES  No Tax on non-Cyprus income and profits of a CIT;  Beneficiaries may be taxable in their country of residence, only upon actual distributions;  No capital gains tax on sale of titles;  No inheritance or wealth taxes applicable;  Low stamp duty;  Possible disapplication of CFC Rules. ASSET PROTECTION  Cyprus courts have exclusive jurisdiction as to the validity of CIT;  The provisions of CIT Law have express Superiority of over any other law, or treaty applicable in Cyprus;  No claim can be filed in relation to the assets of the Trust in the case of bankruptcy or liquidation of the Settlor/ Beneficiary or in cases of institution of legal proceedings against the Settlor/ Beneficiary by his creditors;  Foreign or local succession laws do not apply - Avoidance of forced heirship rules and certainty of succession: Any distribution of Trust property shall be made in accordance to the terms of the Trust deed in the event of death of Settlor or Beneficiary. FLEXIBILITY  Possibility to grant extended powers to Settlors;  Ability on changing the jurisdiction of the Trust;  No statutory limitations on mode of operation, objects, activities or mode of distribution of the Trust;  Flexibility on investments and perpetual accumulation of income;  May be fixed or discretionary.
  • 2. ADDITIONAL BENEFITS  High protection-The legal time limit to challenge the Trust is two years;  Quick to set-up: usually within 2 working days;  No public registries for Trusts;  No filing requirements;  Strict confidentiality: disclosure of any details relating to a CIT is only allowed after a relevant court order. EXAMPLES OF USAGE OF A TRUST 1st EXAMPLE SUCCESSION 2nd EXAMPLE/ PROTECTION  A: - Non-resident UBO (‘NR’) of a Cyprus Company (‘CYCO’) through nominees;  B: - NR of a CIT, shareholder of a CYCO  In the event of the death of: - - A: - law of succession of his country will apply with regards to who will inherit the shares. Further, the business of the CYCO may be paused until the new beneficiary is ascertained - B:-succession laws do not apply and as such the Trustees shall manage and continue the business of the CYCO as per the Trust Deed.  Family asset protection in the case of divorce or complicated family issues or bankruptcy etc.  A couple with children and common business venture gets divorced.  The court ordered for the business venture to be transferred for the benefit of the minors.  In order to protect the minor and the business venture, a CIT can be created with beneficiary being the minor. The mother was the protector and she was also able to manage and safeguard the business venture. 3rd EXAMPLE/ BUSINESS VEHICLE 4th EXAMPLE BUSINESS VEHICLE  Usage of a CIT, as a way to safeguard the continuity of business operations, in the event of settlor or beneficiary attack by authorities. Specifically, CITs may cater for the possibility of automatic removal or disqualification (permanent or temporary) of beneficiaries, in cases where the beneficiaries are found guilty of tax related crimes or are under investigation, or in case such beneficiaries are classified as sanctioned persons.  This method enables the CIT to continue its operations unimpeded and guarantees asset security.  Family owned and managed business.  Elderly CEO, children uninterested in managing the business.  Transfer of the business assets to the Trustees to be managed by the current employees as investment advisors.  Beneficiaries of the Trust are the family whilst the employees are additional beneficiaries and obtain bonus/ pension in accordance with the performance of the Trust. OUR SERVICES  Provision of Trustee, Protector, Advisor;  Advising, Drafting, Structuring & Management of Trusts;  Legal representation in Court Proceedings;  Advising on Tax & Compliance matters. DISCLAIMER This publication has been prepared as a general guide and for information purposes only. It is not a substitution for professional advice. One must not rely on it without receiving independent advice based on the particular facts of his/her own case. No responsibility can be accepted by the authors or the publishers for any loss occasioned by acting or refraining from acting on the basis of this publication