Cyprus Company Formation for Crypto Traders and Investors
Until recently, almost everything written about crypto and Cyprus was an argument about silence — the Income Tax Law did not mention crypto-assets, so people reasoned by analogy and reached whatever conclusion suited them. That argument is over. From the 2026 tax year the Law names crypto-assets directly, puts a rate on disposals, defines what a disposal is, and ring-fences losses. Anyone considering a Cyprus company for crypto trading or investment should start from the text rather than from an article written before it existed. This page sets out what article 20Ε of the Income Tax Law says, marks clearly the questions it leaves open, and is blunt about the line between trading your own book and providing crypto-asset services to other people — because only one of those is something CyPRO One can help with.
Written by Renato Giurea, founder of CyPRO One · Updated 21 August 2026
Regulated work described on this page is carried out by licensed Cyprus partners.
Where you are now
The "Cyprus does not tax crypto" era ended on 1 January 2026
The Income Tax (Amending) (No. 4) Law of 2025 inserted a new article 20Ε into the Income Tax Law, in force from 1 January 2026, and it is short and unambiguous: gains of any person arising from the disposal of crypto-assets are taxed at 8%. The same amending Law added "profit from transactions in crypto-assets falling within article 20Ε" as a listed source of income under Article 5. So the position is no longer inferred — it is written. Two consequences follow immediately for anyone weighing a move. First, a great deal of the commentary you will find is now describing a regime that no longer exists, and it does not always announce its own vintage. Second, an 8% headline is not the same as a simple regime: the definitions, the loss rules and the carve-outs in the rest of the article do most of the real work, and they are where a trading business either fits or does not.
A swap is a disposal, and so is paying for something with a token
Article 20Ε(3)(β) defines "disposal of crypto-assets" as four things: the sale of crypto-assets, the gift of crypto-assets, the exchange of one crypto-asset for another, and the use of a crypto-asset as a means of payment. Read that list against how an active portfolio actually behaves. Rotating from one token into another is a disposal. Paying a supplier in stablecoin is a disposal. Gifting tokens is a disposal. None of those involves a bank transfer, a fiat off-ramp or anything that looks like "taking profit" in ordinary speech, and all of them are events the Law expects you to have measured. That makes exchange and wallet history the primary accounting record for this business, not a supporting document — and it makes reconstructing three years of it after the fact the single most expensive thing you can leave until later.
Trading your own book and running a service for other people are different legal universes
The most consequential distinction on this page is not a tax one. Buying, holding and selling crypto-assets for your own account is an investment activity. Holding assets for other people, running a platform where they trade, executing their orders, exchanging their assets, advising them or managing their portfolios is the provision of crypto-asset services, and in Cyprus that is authorised and supervised territory. Cyprus's national transitional regime for crypto-asset service providers ended on 1 July 2026 — CySEC's own announcement set the authorisation application deadline at 27 February 2026 and confirmed that providers not applying had to submit a wind-down plan, because provision of crypto-asset services would not be permitted after the transitional period without authorisation under Regulation (EU) 2023/1114. If your plan involves other people's assets in any way, that is a specialist regulatory engagement, and it is one CyPRO One does not offer and will not pretend to.
What to get right
Read article 20Ε in full before you rely on the 8%
The rate is one subsection out of five, and the other four decide whether it helps you. Subsection (1) charges gains of any person arising from the disposal of crypto-assets at 8%. Subsection (3)(α) takes the meaning of "crypto-assets" from Article 3(1), point (5) of Regulation (EU) 2023/1114 — the EU markets-in-crypto-assets Regulation — so the boundary of what counts is drawn by an EU definition rather than by the Cyprus tax code, and the article borrows that definition rather than the Regulation's own scope provisions, which is a distinction worth putting to an advisor before you assume a particular asset is inside or outside. Subsection (4) carves out disposals of crypto-assets acquired through mining. Subsection (5) sends any profit from crypto-asset transactions that does not fall within the article back to the general charging provisions in Parts III and V of the Law. One drafting detail is worth flagging honestly rather than glossing. The article immediately above it, article 20Δ, expressly states that the benefit it taxes at 8% is not added to any other income; article 20Ε carries no such subsection. The government's own tax-reform page describes the measure as standalone taxation at 8% on the net profit, which points the same way — but a summary page is not the statute. How the 8% interacts with the rest of a person's or a company's taxable income is a question for a licensed Cyprus tax advisor on your own facts, and we would rather say that than paper over the gap.
Plan for losses being trapped in the year they arise
This is the provision most likely to change how you think about the structure, and it is the one least often mentioned. Article 20Ε(2) says that notwithstanding Article 13 — the general loss relief provision — losses arising from the disposal of crypto-assets may be set off only against gains from the disposal of crypto-assets arising in the same tax year. They are not carried forward against the same person's profits in later years, and they are not surrendered to another company under the group relief provisions in Article 13(4) to (11). Compare that with ordinary trading losses, which the 2026 reform extended to a seven-year carry-forward. For a volatile book that is a structural asymmetry: a year of gains is taxed, a year of losses is simply gone, and the two do not meet. It argues for taking the timing of disposals seriously and for modelling a bad year explicitly rather than assuming relief will appear later. Our ICPAC-registered accounting partner runs that modelling as part of onboarding; the strategic question of whether the structure suits your trading pattern belongs with a licensed Cyprus tax advisor.
Do not assume the 'titles' exemption covers you
A recurring assumption is that crypto rides along with the Cyprus exemption for share disposals. Look at the two provisions together. Article 8(22) of the Income Tax Law exempts "profit from the disposal of titles". Article 2 defines "titles" as shares, debentures, bonds, founders' and other securities of companies or other legal persons incorporated under the law in the Republic or abroad, and rights in them. Crypto-assets are not in that list, and the 2026 reform did not add them to it — instead it added a separate definition of Regulation (EU) 2023/1114 to Article 2 and gave crypto its own charging article at 20Ε. So the structure of the Law now treats crypto-asset gains as a taxed category with its own rate, not as an exempt one. Where a particular instrument is genuinely a security rather than a crypto-asset, that is a characterisation question with real consequences and it needs advice, not a guess.
Know that mining, staking and lending sit outside the disposal rule
Article 20Ε(4) states that the article does not apply to the disposal of crypto-assets acquired through carrying on mining activity. That does not make mining tax-free; it means the 8% disposal rate is not the provision that governs it, and subsection (5) directs anything outside the article to the general charging rules in Parts III and V. Staking rewards, lending yield and airdrops are a related but distinct question: none of them is one of the four acts listed in the definition of disposal, so on the face of the Law they are not taxed by article 20Ε either. Which head of charge does apply to them is not spelled out in the article, and this page is not going to invent an answer for a page a stranger might rely on. What we can say usefully is that the reporting regime takes a wider view than the taxing one — Annex VI to the Administrative Cooperation in the Field of Taxation Law defines a crypto-asset service to include the staking and the lending of crypto-assets — so activity that article 20Ε does not tax as a disposal can still be reported. Put the characterisation to a licensed Cyprus tax advisor before the first return, not after.
Assume your exchange is reporting, because from 2026 it is
Cyprus transposed the EU's crypto-asset reporting rules by Law 38(I)/2026, published in the Official Gazette on 27 March 2026, which inserted article 7ΣΤ into the Administrative Cooperation in the Field of Taxation Law and is deemed to have come into force on 1 January 2026. Under it, a Reporting Crypto-Asset Service Provider applies the due-diligence procedures and reporting requirements in Annex VI, and the Tax Department exchanges the resulting information automatically with the competent authorities of the other member states. The information reported per reportable person includes name, address, member state or states of residence, tax identification numbers and, for individuals, date and place of birth. The practical meaning is simple: the position you take on your own return should be one you would be comfortable seeing matched against a third-party feed, because that is now the design. Building a clean transaction record from the beginning is cheaper than defending an estimated one later.
Budget realistically for the account-opening step
Banking is where crypto-related businesses most often stall, and it is worth being honest about what is on offer. CyPRO One's practical banking service is help preparing and reviewing a Revolut Business application — not a traditional Cyprus bank account, and we are not affiliated with Revolut. The onboarding flow requires the company representative to submit it; we help you assemble the file. Approval, timelines and appetite for any particular activity are entirely Revolut's decision and cannot be guaranteed by us. Expect the source-of-funds and source-of-wealth documentation to be the substantial part of the work: the EU information-on-transfers regime for crypto-assets, Regulation (EU) 2023/1113, is expressly part of the obligations CySEC has confirmed continue to apply to registered providers, and the same expectations propagate through the institutions that serve this sector. Compile the history — exchange statements, wallet records, the origin of the original capital — before you apply rather than in response to a request.
Be clear about which side of the CySEC line your plan sits on
Regulation (EU) 2023/1114 is the framework Cyprus now applies to markets in crypto-assets, and the Minister of Finance has appointed CySEC and the Central Bank of Cyprus as the competent authorities for it. Since the end of the national transitional regime on 1 July 2026, continuing to provide crypto-asset services is conditional on holding authorisation under that Regulation. CyPRO One does not offer, coordinate or introduce cryptocurrency, VASP or CySEC licensing work of any kind — it is outside our service list and outside our competence, and any page that tells you otherwise is selling you something. What we do coordinate, through licensed Cyprus partners, is the ordinary company: formation with the Registrar through our licensed corporate services partner, accounting and audit coordination through our ICPAC-registered partner, and the annual compliance calendar. If your model turns out to need authorisation, the honest answer is that you need a specialist Cyprus regulatory law firm, and we will say so rather than take the engagement.
This page is for information only
Nothing on this page constitutes legal or tax advice. Tax law is subject to change. The effect of any of it on your circumstances depends on how your activity is characterised, which of your transactions are disposals within article 20Ε, and whether any part of what you do amounts to providing crypto-asset services to other people. Always seek independent professional advice before making residency, structuring, or filing decisions based on this content.
Services referred to on this page are delivered through licensed Cyprus partners — a Cyprus Bar Association registered lawyer, an ICPAC-registered accounting firm, and/or a licensed Cyprus corporate services provider, as applicable. CyPRO One coordinates the engagement and acts as your single point of contact.
Frequently Asked Questions
How does Cyprus tax crypto gains in 2026?
Article 20Ε of the Income Tax Law, inserted by article 13 of the Income Tax (Amending) (No. 4) Law of 2025 and in force from 1 January 2026, charges gains of any person arising from the disposal of crypto-assets at 8%. "Crypto-assets" takes the meaning given in Article 3(1), point (5) of Regulation (EU) 2023/1114. The same amending Law added "profit from transactions in crypto-assets falling within article 20Ε" as a listed source of income under Article 5. Two honest caveats. The article itself does not say the 8% is a standalone final charge — the article immediately before it says exactly that about its own 8% rate, and article 20Ε does not, although the government's tax-reform page describes the measure as standalone taxation at 8% on the net profit — so how it sits alongside your other income is a question for a licensed Cyprus tax advisor rather than for this page. And profit from crypto-asset transactions that does not fall within the article is taxed under the general provisions of Parts III and V instead.
Is swapping one token for another a taxable event in Cyprus?
On the face of the Law, yes. Article 20Ε(3)(β) defines "disposal of crypto-assets" as the sale of crypto-assets, the gift of crypto-assets, the exchange of one crypto-asset for another, and the use of a crypto-asset as a means of payment. A crypto-to-crypto exchange is listed expressly, and so is spending a token. That means the taxable events in an active portfolio can vastly outnumber the times money moved to or from a bank, and it makes your exchange and wallet export the primary record rather than a supplementary one. Practically: export continuously, keep the acquisition cost of every position, and give your accountant the full history rather than a year-end balance. Our ICPAC-registered accounting partner works from that record; if it does not exist, reconstructing it is the expensive part of onboarding.
Can I offset a bad crypto year against a good one?
Not across years. Article 20Ε(2) provides that, notwithstanding Article 13, losses arising from the disposal of crypto-assets may be set off only against gains from the disposal of crypto-assets arising in the same tax year, are not carried forward against the same person's profits in later years, and are not surrendered to another company under the group relief provisions in Article 13(4) to (11). So the relief is ring-fenced twice over — to crypto disposals, and to the year they happen in. That is materially narrower than ordinary losses, whose carry-forward period the same 2026 reform extended to seven years. If your trading pattern produces alternating years, model the effect explicitly before you commit to a structure, and take advice on timing from someone licensed to give it.
What about mining, staking, lending and airdrops?
Mining is expressly carved out: article 20Ε(4) says the article does not apply to disposals of crypto-assets acquired through carrying on mining activity, which means the 8% disposal rate is not what governs it and subsection (5) points anything outside the article at the general charging provisions in Parts III and V of the Law. Staking rewards, lending yield and airdrops are a separate question, and the honest answer is that the Law does not deal with them head-on: none of them is one of the four acts in the definition of disposal, so article 20Ε does not tax them, and which head of charge does is not specified. Note that the reporting rules cast a wider net than the taxing ones — Annex VI to the Administrative Cooperation in the Field of Taxation Law brings staking and lending inside the definition of a crypto-asset service. Get the characterisation from a licensed Cyprus tax advisor before your first return.
Aren't crypto gains exempt in Cyprus like share disposals?
No, and the two provisions are worth reading side by side. Article 8(22) of the Income Tax Law exempts profit from the disposal of "titles", and Article 2 defines titles as shares, debentures, bonds, founders' and other securities of companies or other legal persons incorporated in the Republic or abroad, and rights in them. Crypto-assets do not appear in that definition. The 2026 reform did not add them to it either — it added a definition of Regulation (EU) 2023/1114 to Article 2 and gave crypto-asset disposals their own charging article at 20Ε with its own 8% rate. So the design of the Law is that crypto is taxed, not exempt. Whether a specific tokenised instrument is in substance a security rather than a crypto-asset is a genuine characterisation question with real consequences, and it needs advice rather than an assumption.
Do I need a CySEC licence, and can CyPRO One arrange one?
CyPRO One does not offer or coordinate cryptocurrency, VASP or CySEC licensing work — it is on our list of services we do not provide, and we will not take the engagement. On whether you need one: the line is whether you provide crypto-asset services to other people. Trading and investing your own assets is not that. Custody, running a trading platform, exchanging or executing for clients, advice and portfolio management are. Cyprus's national transitional regime for crypto-asset service providers ended on 1 July 2026, with an authorisation application deadline of 27 February 2026, and CySEC confirmed that providers that did not apply had to submit a wind-down plan because provision of crypto-asset services would not be permitted afterwards without authorisation under Regulation (EU) 2023/1114. If that is your model, engage a specialist Cyprus regulatory law firm directly.
Will my exchange report my account to the Cyprus Tax Department?
If it is a Reporting Crypto-Asset Service Provider, that is exactly the design. Law 38(I)/2026 inserted article 7ΣΤ into the Administrative Cooperation in the Field of Taxation Law with effect deemed from 1 January 2026: reporting providers apply the due-diligence procedures and reporting requirements in Annex VI, and the Tax Department communicates the resulting information to the competent authorities of the member states concerned through automatic exchange. The reported set includes each reportable user's name, address, member state or states of residence, tax identification numbers and, for individuals, date and place of birth, alongside the transaction information. The point for you is not that reporting is new in principle but that the crypto-specific feed starts with the 2026 year, so the first returns filed under the new tax article are also the first ones with a matching data source behind them.
Can I open a business account for a crypto-related company?
Sometimes, and never on a promise from us. CyPRO One's banking service is help preparing and reviewing a Revolut Business application rather than a traditional Cyprus bank account, and we are not affiliated with Revolut. Revolut's own onboarding requires the company representative to submit the application; we help you assemble and check the file. Whether an application is accepted, how long it takes, and what appetite exists for any particular activity are entirely Revolut's decisions and cannot be guaranteed. What consistently makes the difference is the evidence pack — a documented source of the original capital, complete exchange and wallet history, and a coherent written description of what the business actually does. The EU regime on information accompanying transfers of crypto-assets, Regulation (EU) 2023/1113, sits behind much of that scrutiny, and it is not going to loosen.
Sources
Every figure and rule on this page traces to a primary authority: the legislation, court decisions and official guidance cited below, linked so you can read the wording yourself. Check them rather than take our word for it.
Article 20Ε of the Income Tax Law 118(I)/2002 (consolidated), "Gains from transactions in crypto-assets": (1) gains of any person arising from the disposal of crypto-assets are taxed at eight per cent (8%); (2) notwithstanding Article 13, losses from the disposal of crypto-assets may be set off only against gains from the disposal of crypto-assets arising in the same tax year, are neither carried forward nor set against the same person's profits in later years, and are not surrendered to another company under Article 13(4) to (11); (3)(α) "crypto-assets" is interpreted in accordance with paragraph 5 of subsection 1 of Article 3 of Regulation (EU) 2023/1114; (3)(β) "disposal of crypto-assets" means the sale of crypto-assets, the gift of crypto-assets, the exchange of one crypto-asset for another and the use of a crypto-asset as a means of payment; (4) the Article does not apply to disposals of crypto-assets acquired through carrying on mining activity; (5) any profit from transactions in crypto-assets not falling within the Article is taxed under Parts III and V of the Law.
https://www.cylaw.org/nomoi/enop/ind/2002_1_118/section-sce804a257-bc56-297e-343c-322a5efaf1aa.htmlCommencement and insertion: the Income Tax (Amending) (No. 4) Law of 2025, N.244(I)/2025, Official Gazette No. 5070 of 31 December 2025. Article 13 inserts new articles 20Δ, 20Ε and 20ΣΤ immediately after article 20Γ of the basic Law; article 3 adds paragraph (η), "profit from transactions in crypto-assets falling within the provisions of article 20Ε", to both subsection (1) and subsection (2) of Article 5; article 2(β) adds the definition of Regulation (EU) 2023/1114 to Article 2; and article 25 brings the Law into force on 1 January 2026, except paragraph (στ) of article 4. Article 20Δ(4) — the article immediately preceding 20Ε — expressly provides that the benefit taxed at 8% under it is not added to any other income; article 20Ε contains no equivalent provision.
https://www.cylaw.org/nomoi/arith/2025_1_244.pdfCrypto-asset profit as a source of income: Article 5 of the Income Tax Law, subsections (1)(η) and (2)(η) — profit from transactions in crypto-assets falling within the provisions of article 20Ε.
https://www.cylaw.org/nomoi/enop/ind/2002_1_118/section-sc93332b0a-7407-cc82-00eb-e1d2782e7ad1.htmlThe exemption for disposals of "titles" does not reach crypto-assets: Article 8(22) of the Income Tax Law exempts "profit from the disposal of titles", and Article 2 defines "titles" as shares, debentures, bonds, founders' and other securities of companies or other legal persons incorporated under the law in the Republic or abroad, and rights in them. Article 2 also now carries the definition of Regulation (EU) 2023/1114 added by the 2026 reform.
https://www.cylaw.org/nomoi/enop/ind/2002_1_118/section-sc83db2317-eab7-158b-ebde-c33b848e8709.htmlDefinition of "titles" and of Regulation (EU) 2023/1114 in the interpretation section: Article 2, Income Tax Law 118(I)/2002 (consolidated).
https://www.cylaw.org/nomoi/enop/ind/2002_1_118/section-sca5096950-5752-1798-08d7-b632dc2a4686.htmlEnd of the Cyprus national transitional regime for crypto-asset service providers: CySEC press release of 23 December 2025, "MiCA licence applications due by 27 February 2026" — CASPs providing services under the national framework could continue until their application was approved or rejected or, in any event, until the end of the transitional period on 1 July 2026, whichever came first; those that did not apply by the deadline were required to submit a wind-down plan, as the provision of crypto-asset services would no longer be permitted after the transitional period, any continuation being conditional on obtaining MiCA authorisation. The release also records that registered providers remained subject to the obligations arising from Regulation (EU) 2023/1113.
https://www.cysec.gov.cy/CMSPages/GetFile.aspx?guid=3c2571bc-1e2f-4537-b139-bc6bdc375719CySEC's markets-in-crypto-assets regulatory framework page, including the Minister of Finance's notification appointing CySEC and the Central Bank of Cyprus as the competent authorities for the application of Regulation (EU) 2023/1114.
https://www.cysec.gov.cy/en-GB/legislation/services-markets/Markets-in-crypto-assets/Automatic exchange of crypto-asset information: Article 7ΣΤ of the Administrative Cooperation in the Field of Taxation Law 205(I)/2012 (consolidated) — a Reporting Crypto-Asset Service Provider meets the reporting requirements and applies the due diligence procedures in Sections II and III of Annex VI, and the competent authority in the Republic communicates the information listed in subsection (3), by automatic exchange, to the competent authorities of the member states concerned. The reported set includes each reportable user's name, address, member state or states of residence, tax identification numbers and, for an individual, date and place of birth.
https://www.cylaw.org/nomoi/enop/ind/2012_1_205/section-scce404668-e86b-acc3-cd97-5c7afcb873b0.htmlTransposition and commencement: the Administrative Cooperation in the Field of Taxation (Amending) Law of 2026, N.38(I)/2026, Official Gazette No. 5081 of 27 March 2026. Article 7 inserts the new article 7ΣΤ immediately after article 7Ε; section 20(1) provides that, subject to subsection (2), the Law is deemed to have come into force on 1 January 2026. Annex VI defines "Crypto-Asset Service" as a crypto-asset service as defined in Article 3(1), point (16) of Regulation (EU) 2023/1114, including the staking and the lending of crypto-assets.
https://www.cylaw.org/nomoi/arith/2026_1_038.pdfOfficial Cyprus government tax reform page for businesses and legal persons, which lists among the 2026 measures "Κρυπτοστοιχεία: αυτοτελής φορολόγηση 8% στο καθαρό κέρδος" — crypto-assets: standalone taxation at 8% on the net profit — alongside corporate tax from 12.5% to 15%, tax on actual dividends from 17% to 5%, abolition of deemed dividend distribution, the special 8% rate for stock options, and "Επέκταση της περιόδου μεταφοράς ζημιών στα επτά έτη", the extension of the loss carry-forward period to seven years.
https://www.gov.cy/taxreform/forologika-ofeli-gia-epixeiriseis-nomika-proswpa/
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