Qualifying assets under the new regime include:
- copyrighted software programs, and
- other intangible assets that are non-obvious, useful and novel.
Qualifying assets do not include trademarks and copyrights.
Qualifying persons include:
- Cyprus tax resident taxpayers,
- Tax resident
- Permanent Establishments (PEs) of non-tax resident persons
- Foreign PEs that are subject to tax in Cyprus.
Qualifying profits are calculated in accordance with the nexus fraction.
The nexus fraction
The nexus fraction is used to determine the amount of qualifying profits that will give the relevant deduction to the taxpayer.