On 9 April 2026, the Cyprus Tax Department issued a circular specifying the jurisdictions for
which the defensive tax measures purported for low – tax jurisdictions (i.e. tax on payments of
dividends from Cyprus and nondeducibility of interest/royalties). The measure were
introduced as part of the Tax Reform package.
The jurisdictions are the following:
1. Anguilla
2. Vanuatu
3. Bermuda
4. British Virgin Islands
5. Guernsey
6. Cayman Islands
7. Turks and Caicos Islands
8. Isle of Man
9. Bahamas
10. Bahrain
11. Jersey
The list is based on specific criteria, which have not been made public by the Cyprus Tax
Department. The criteria will be reviewed and updated on an annual basis.
