Do Greek CFC rules apply to my Cyprus company?
Short answer
They can. Greek rules on controlled foreign companies cover individuals as well as companies: they apply when you control more than half of the company, it pays less than half the tax it would pay in Greece, and more than 30% of its income is passive.
They do not apply to an EU company with a substantive economic activity, with real staff, equipment, assets and premises; the tax office has to show that this activity is missing.
With Greek corporate tax at 22%, half is 11%, so a Cyprus company that actually pays the 15% corporate tax would normally pass that test.
Sources
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 Greece and in Cyprus before you act on it.
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