IP Box Structuring· OECD Nexus approach

Cyprus IP Box
Structuring & Advisory

The Cyprus IP Box can reduce the effective tax rate on qualifying IP income to approximately 2.5–3%. We assess eligibility, structure the arrangement, document the nexus, and handle the annual compliance.

What's Included

Full IP Box Service

From eligibility assessment to annual compliance filing.

  • IP Box eligibility pre-assessment
  • Qualifying intangible asset identification
  • Software copyright and patent analysis
  • R&D expenditure documentation
  • Nexus fraction calculation
  • IP Box election filing
  • IP licensing structure advice
  • Ongoing R&D documentation management
  • Annual IP Box compliance
  • IP ownership structure review
  • Intercompany IP licensing arrangements
  • Co-ordination with technical R&D teams

Qualifying IP Asset Types

  • Software (patented or copyrighted)
  • Patents
  • Utility models
  • Supplementary protection certificates
  • Plant breeders' rights
  • Orphan drug designations
  • Non-obvious, novel utility models

Trademarks, brands and marketing IP do not qualify.

Effective Tax Rate on IP Income

Standard rate (from 2026)15%
IP Box deduction80% of qualifying income
Effective rate on IP income~3%*

* Assumes full nexus fraction. Actual effective rate depends on qualifying expenditure ratio and individual circumstances.

Important: Eligibility Must Be Assessed

Not all software or IP businesses qualify. The Cyprus IP Box requires genuine R&D expenditure, qualifying intangible assets, and proper documentation. We always conduct a formal eligibility assessment before advising clients to proceed.

FAQ

IP Box Questions

What is the Cyprus IP Box?

The Cyprus IP Box (Intellectual Property Box) allows companies with qualifying intellectual property assets to benefit from a significantly reduced effective tax rate on income derived from those assets. Under the regime, up to 80% of qualifying IP income may be deducted, resulting in an effective tax rate on that income of approximately 2.5% (based on the pre-2026 12.5% rate; from 2026, the effective rate will be approximately 3% based on the new 15% standard rate).

What types of IP qualify for the Cyprus IP Box?

Qualifying assets include patents, copyrighted software, utility models, plant breeders' rights, supplementary protection certificates, and orphan drug designations. Trademarks, brands, and marketing-related IP do not qualify under the OECD nexus approach.

What is the nexus approach?

The OECD nexus approach links the IP Box benefit to actual R&D activity. The fraction of qualifying income that benefits from the regime is determined by the ratio of qualifying R&D expenditure incurred by the company to total expenditure on the IP. This means that companies must have genuine R&D activities to claim the full benefit.

Does my SaaS/software business qualify?

Potentially yes — if your software is copyrighted (which most original software is automatically) and you have genuine R&D expenditure associated with its development. However, eligibility must be assessed on a case-by-case basis. We recommend an IP Box pre-check before making any assumptions.

Does IP need to be developed in Cyprus?

Not necessarily, but the R&D expenditure used to calculate the nexus fraction must have been incurred directly by the company (or contracted to unrelated third parties). Outsourcing to related parties limits the nexus fraction. Physical presence in Cyprus is not strictly required but strengthens the overall position.

IP Box eligibility depends on specific asset types, R&D activities, and individual circumstances. This page is for general information only and does not constitute tax advice. Always obtain a formal assessment before implementing any IP Box structure.

Is Your Business IP Box Eligible?

Book a formal IP Box eligibility assessment. We'll review your IP assets, R&D activities, and structure options.

Book an IP Box Assessment