What substance means in practice
Typically: a local director with a real role, documented resolutions, a reachable business address, accounts and, depending on the model, staff, premises or demonstrable operations. The mix depends on the business. An IP-holding Ltd needs a different trail from an operating software firm.
Management and control
Many states tie corporate residence to the place of effective management. Video calls from the home state in which every resolution is taken, while Larnaca only signs, is the pattern audits look for. CyStarter designs reporting lines so decisions can credibly happen in Cyprus.
What banks and tax authorities typically want to see
No checklist replaces the individual case, but the trail is recurring: the director’s employment contract and pay, minutes of material resolutions, demonstrable presence, ongoing accounts, a bank account that fits the model, and an address at which the company can be reached. Buying a registry address is not buying substance.
Substance and the IP Box belong together
An IP Box without nexus and without a locally anchored IP company is contradictory. Substance, the director model and tax structuring belong together. Advertising rates in isolation would be incomplete.
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This article is general information and does not replace legal, tax or investment advice in any individual case.