Cyprus CGT and Listed Shares

The Cyprus tax reform introduces amendments to the Cyprus Capital Gains Tax (“CGT”) framework relating to:

• shares listed on regulated markets, and
• shares listed on unregulated markets

where the relevant companies directly or indirectly own Cyprus immovable property.

The revised provisions affect:

• property-rich companies,
• listed investment structures,
• real estate holding companies, and
• investors disposing of listed shares connected with Cyprus immovable property.

The amendments distinguish between:

• regulated markets, and
• unregulated markets

for purposes of the Cyprus CGT treatment.

Shares Listed on Regulated Markets

Under the revised framework, no Cyprus CGT is generally imposed on gains arising from the disposal of shares listed on:

• a regulated market of a recognised stock exchange.

The Cyprus legislation refers to the:

• Investment Services and Activities and Regulated Markets Law

for purposes of determining the meaning of a regulated market.

Accordingly, disposals of qualifying listed shares on recognised regulated exchanges generally remain exempt from Cyprus CGT even where the underlying company directly or indirectly owns Cyprus immovable property.

Shares Listed on Unregulated Markets

The revised framework also introduces a separate regime for shares listed on:

• unregulated markets of recognised stock exchanges.

Under the new rules:

• no Cyprus CGT is generally imposed where the total value of disposals during a calendar year does not exceed:
  • €50,000.

However, where the total value of disposals exceeds:

• €50,000 within the same calendar year,

Cyprus CGT applies at the normal rates on the amount exceeding the relevant threshold.

The taxation point arises at the time the relevant threshold is exceeded.

Property-Rich Companies

The revised provisions remain particularly relevant where the listed company:

• directly owns Cyprus immovable property, or
• indirectly derives value from Cyprus immovable property,

subject to the applicable property-rich thresholds under the Cyprus CGT framework.

The interaction between:

• listed share exemptions,
• property-rich company rules, and
• indirect property ownership

therefore remains particularly important in practice.

Transitional Exemption for Existing Holdings

The revised framework also introduces transitional protection for shares:

• held as at 31 December 2025,
• listed on an unregulated market of a recognised stock exchange, and
• owned by the disposer at the relevant time.

Under the transitional provisions, gains arising on the disposal of such shares remain exempt from Cyprus CGT regardless of the disposal value.

The transitional protection therefore preserves the historical exemption treatment for certain pre-existing investments.

Practical Impact of the Reform

The revised framework may significantly affect:

• listed property investment structures,
• investors in unregulated markets,
• Cyprus Stock Exchange structures,
• real estate investment companies, and
• property-rich listed entities.

The amendments may also reduce part of the historical tax attractiveness of:

• unregulated market listings,

particularly where disposal values exceed the new annual threshold.

At the same time, the continued exemption applicable to regulated markets preserves the attractiveness of qualifying listed investment structures.

Contact Rightax

For further information or professional assistance regarding the Cyprus tax reform, international tax matters or Cyprus corporate structures, please contact the Rightax tax advisory team.

+357 99 108 510

[email protected]

The above information is provided for general guidance only. It does not constitute legal or tax advice. Always consult a qualified professional for advice tailored to your specific circumstances