A trust may be defined as the obligation of a person (i.e. the trustee) to whom property is transferred by the owner of the property and the creator of the trust (i.e. the settlor), to hold and manage such property for a defined period according to the wishes of the settlor, oral or written as expressed in a Deed of Trust or a Will, in favour of a specified person or persons or class of persons (i.e. the beneficiaries). A trust is not a separate legal entity.
International Trusts
The Law defines an International Trust as being a trust in respect of which:
(a) The Settlor is not a tax resident in Cyprus during the calendar year which precedes the year of creation of the trust;
(b) At least one of the Trustees from time to time is a tax resident in Cyprus during the trust period; and
(c) None of the Beneficiaries are tax residents in Cyprus during the calendar year which precedes the year of creation of the trust.
According to applicable law:
(i) Where the beneficiary is resident in Cyprus, the income and profits of a Cyprus International Trust which are earned or deemed to be earned from sources within and outside of Cyprus, are subject to every form of taxation imposed in Cyprus.
(ii) Where the beneficiary is not a resident of Cyprus, the income and profits of a Cyprus International Trust which are earned or deemed to be earned from sources within Cyprus, are subject to every form or taxation imposed in Cyprus.