Can I run my Cyprus company from Germany?
Short answer
Not without German tax: a company whose place of management, the centre of its top-level management, is in Germany pays full German corporate tax on all its income, and its management site is a German permanent establishment.
Under the Germany–Cyprus treaty, a company resident in both countries is treated as resident where it is effectively managed. A Cyprus company run day to day from a German home office therefore belongs to Germany for tax.
For the company to be taxed in Cyprus, the board has to meet and decide here, with the substance that goes with it.
Sources
- Abgabenordnung, §10: Geschäftsleitung (gesetze-im-internet.de) gesetze-im-internet.de
- Körperschaftsteuergesetz, §1 (gesetze-im-internet.de) gesetze-im-internet.de
- Bundestag printed paper 17/6259: the Germany–Cyprus agreement and its text dserver.bundestag.de
Information, not advice. This answer describes the published rules as they stand on 12 October 2026, checked against the sources listed. Tax and residence rules depend on your own circumstances and change; check your position with a tax adviser qualified in Germany and in Cyprus before you act on it.
Ready when you are.
Tell us where you are, where you are going and what the company will do. We reply with your price, in writing, and a time to talk.
