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  1. INTRODUCTION
  2. WHAT IS A TRUST?
  3. TYPES OF TRUST
  4. I.T.L.
  5. TAXATION OF INTERNATIONAL TRUST
  6. HOW A TRUST IS CREATED
  7. WHERE THE TRUST FUND IS SITUATED
  8. WHAT THE TRUST FUND INCLUDES
  9. USES OF INTERNATIONAL TRUSTS
  10. SUITABILITY OF CYPRUS
  11. PROFESSIONAL EXPERTS REACTIONS
  1. Short title
  2. Interpretation
  3. Validity of an international trust
  4. Presumption against avoidance of an international trust
  5. Duration of an international trust
  6. Validity of direction for the accumulation of income
  7. Charitable trusts and purpose trusts
  8. Authorised investments
  9. Power to change the applicable law of an international trust
  10. Variation of an international trust by the Court
  11. Confidentiality relating to international trusts
  12. Taxation of international trusts
  13. Application of this Law
  14.   Saving of existing laws
  15. Registration not compulsory

Although there are nowhere in the texts categories of the various types of trusts existing and allowed under Cyprus Law, nevertheless, one may say that there are only three (3) types:

  • local trusts;

  • offshore trusts; and

  • international trusts

    1. LOCAL TRUSTS

      • the Sector or the beneficiary is a Cypriot permanent resident; and

      • there is immovable property in Cyprus

    2. OFFSHORE TRUSTS

      • the sector must be non-resident

      • the beneficiaries must be non-resident

      • none of the trustees is a Cyprus company or a Cypriot

      (Offshore trusts enjoy the same tax benefits as International trusts)

    3. INTERNATIONAL TRUST

      (Formed under the provisions of the I.T.L.)

      This is the only kind of trust which, is of interest to non-residents.  In international trusts:

      • the Settlor must be non-resident;

      • the beneficiary or the beneficiaries (except charitable institutions) must be non-resident;

      • no immovable property in Cyprus is included among the trust fund; and

      • at least one of the trustees is a Cypriot or a Cyprus offshore company (the Cypriot trustee must disclose to the Central Bank of Cyprus evidence or extracts from the trust instrument proving the above requirements)

      To form a Cyprus offshore company to act as a trustee is very easy and the Central Bank of Cyprus always gives its permission in bona fida cases.  The owners or the beneficial owners (if nominees shall be used) of the offshore company, as well as its directors, may be foreigners.  My colleague has already spoken about the legal and tax status of Cyprus offshore companies and additional information can also be found in the various brochures displayed outside.


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