1. Scope
These Terms and Conditions (“Terms”) govern all contracts and services between the Client and Privacy Management Group Ltd, a company incorporated in the Republic of Cyprus with registration number Cyprus HE 147411, having its registered office at 61-63 Lord Byron Street, Level 5 & 6, 6023 Larnaca, Cyprus (“PMG”), with ICPAC registration no. E411
Within the wider Privacy Management Group corporate structure, PMG acts as the responsible entity for clients whose services are provided in or from Cyprus, including company formation, tax residency and Non-Dom planning, accounting and tax compliance, relocation, and office services delivered in the Republic of Cyprus.
Where a client instructs PMG in relation to services provided in another jurisdiction — for example the United Arab Emirates, Ireland, or a jurisdiction served through a cooperation partner — those services are provided under the terms and conditions, and by the entity, applicable in that jurisdiction, and PMG will identify the responsible entity to the Client before the relevant engagement begins.
PMG serves clients from various jurisdictions, economic areas, and nationalities. These Terms apply regardless of the Client’s domicile or nationality, subject always to any mandatory rule of Cyprus or EU law that cannot be excluded or varied by agreement.
PMG provides its services exclusively to Clients who qualify as entrepreneurs, i.e. acting in the course of a trade, business, or profession. PMG does not knowingly contract with consumers acting for purposes outside their trade, business, or profession, and these Terms are drafted on a business-to-business (B2B) basis. If a Client nonetheless qualifies as a consumer under applicable Cyprus or EU law, the mandatory consumer-protection provisions of that law apply and take precedence over any conflicting clause in these Terms.
These Terms also govern all future business between PMG and the Client, unless otherwise expressly agreed; no fresh reference to them is required for subsequent assignments.
These Terms take effect and become binding on the Client from whichever of the following happens first: the Client signs an engagement letter, order confirmation, or offer referring to these Terms; the Client submits an instruction, onboarding form, or application requesting PMG’s services; the Client makes a payment to PMG in connection with the services; or PMG begins work at the Client’s request. Where the Client is not a natural person, the individual who gives instructions to PMG on the Client’s behalf confirms, by doing so, that they are authorised to bind the Client to these Terms.
Unless PMG has expressly agreed otherwise in writing, PMG contracts with the individual who approaches PMG to request services in their own personal capacity, and does not act on behalf of an undisclosed third party. Where that individual instructs PMG to form or manage a company or other structure, the resulting company or structure becomes a party to these Terms in addition to, and not instead of, the individual, in accordance with Section 4.6.
2. Subject Matter and Description of Services
This contract covers PMG’s provision of consulting, incorporation, tax and accounting, and administrative services in connection with Cyprus company formation and management, Cyprus tax residency (including the Non-Dom regime), relocation to Cyprus, and related office and postal services.
Where the engagement also involves another jurisdiction — for example a UAE, Irish, or other group entity, or an external cooperation partner — the Client agrees that the relevant component of the service may be carried out by that group company or partner, subject to the terms applicable to that jurisdiction. PMG will remain the Client’s primary point of contact for the Cyprus-related elements of the engagement, but does not, by coordinating the overall mandate, assume responsibility for services that another group entity or partner provides under its own terms and its own regulatory responsibility, unless PMG has expressly agreed in writing to assume that responsibility.
The precise scope of services is set out in the relevant individual contract, signed offer, and/or service description. PMG does not guarantee any particular legal, tax, or administrative outcome unless it has expressly confirmed this in writing. In particular, PMG cannot guarantee the granting of a tax residency certificate, work or residence permit, or the opening of a bank account, as these decisions rest solely with the competent Cyprus authority or institution.
PMG may engage qualified employees, associates, or subcontractors to help perform the contract, and remains responsible for their proper supervision.
3. Client Obligations
The Client agrees to support PMG fully in carrying out the commissioned services, in particular by providing all necessary information, documents, declarations, and authorisations promptly, completely, and accurately, including for the purposes of PMG’s Client Due Diligence and Know Your Customer obligations under the Cyprus Prevention and Suppression of Money Laundering and Terrorist Financing Law.
Proper delivery of the service depends on the Client’s active cooperation. Any delay, extra work, or other disadvantage caused by late, incomplete, or incorrect cooperation is the Client’s responsibility, and PMG may adjust deadlines or charge additional fees to reflect the extra work involved.
The Client must notify PMG of any change to its contact details, corporate structure, directors, shareholders, or beneficial owners without delay, and in any event within seven (7) working days, in writing or by email — this is necessary, among other things, so PMG can keep the Cyprus Registrar of Companies and the Cyprus beneficial ownership register up to date where PMG is responsible for these filings.
PMG will provide the Client with certain documents from time to time — including contracts, tax assessments, financial statements, or other declarations — which the Client must review promptly on receipt for accuracy and completeness. Any discrepancy or objection must be raised with PMG in writing within seven (7) working days; if PMG hears nothing within that period, the contents are treated as approved. This does not affect any right the Client has under mandatory law to challenge inaccurate information at a later date.
Where PMG provides electronic access credentials (for example, to a client portal), the Client must keep them confidential, protect them from third-party access, and update them regularly, and must notify PMG without delay of any suspected misuse.
Any registered office, business address, or mail-forwarding service PMG provides may be used only for its agreed contractual purpose. Misuse — in particular to misrepresent tax residence or economic substance in Cyprus, or to circumvent regulatory obligations — is prohibited and entitles PMG to terminate the contract for cause.
The Client remains responsible for meeting all legal, tax, and regulatory deadlines that apply to it, including in relation to Cyprus tax returns, the annual levy, beneficial ownership filings, and any visa or residence permit renewal. PMG accepts no liability for any omission, fine, default interest, or other disadvantage arising from the Client’s lack of cooperation or delayed response, save where PMG was itself instructed and paid to meet that specific deadline and failed to do so through its own fault.
Where PMG is to make a payment to an authority or third party on the Client’s behalf (for example, government fees, the annual company levy, or licence fees), the full amount must reach the account PMG specifies at least five (5) working days before the due date, unless a different period is agreed in writing. The Client bears all bank charges, transfer costs, and currency-conversion charges. If payment is late or short, PMG may suspend the relevant service or, having warned the Client, proceed at the Client’s risk as to any resulting late-filing consequence.
The Client must give all instructions to PMG clearly, and must clearly flag any change, repetition, or correction as such. PMG is not obliged to chase the Client for missing or unclear information; the Client is responsible for the timely, complete, and verifiable provision of all relevant documents, and PMG may suspend or decline to provide a service, in whole or in part, if the necessary documents are missing, late, or incomplete.
The Client represents and warrants, on a continuing basis throughout the engagement, that neither the Client, nor any beneficial owner, director, or other individual connected with the Client, is a person or entity designated, listed, owned, or controlled by a person designated under any applicable sanctions regime (including those maintained by the European Union, the United Nations, the United Kingdom, or the United States of America), and that the Client’s funds and activities do not derive from, and are not connected with, money laundering, terrorist financing, bribery, corruption, tax evasion, or any other financial crime. The Client must notify PMG immediately if this ceases to be true. PMG may decline to act, suspend the provision of services, or terminate the contract immediately and without liability if PMG reasonably believes this representation is or has become inaccurate, or if continuing to act would expose PMG to a breach of applicable sanctions, anti-money-laundering, or anti-bribery law.
4. Liability
Nothing in these Terms excludes or limits PMG’s liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot lawfully be excluded or limited under the law of the Republic of Cyprus.
4.1 General Limitation of Liability
Subject to Section 4 above, PMG’s liability for loss caused by negligence in the performance of the services is limited to loss that was reasonably foreseeable at the time the relevant contract was entered into. PMG is not liable for indirect loss, loss of profit, or loss of business opportunity, except where such loss arises from PMG’s own wilful default or gross negligence.
4.2 Liability for Services Performed by Other Group Companies or Partners
Where a service is in substance provided by another group company (for example Privacy Management Group FZ-LLC in the UAE, or an Irish affiliate) or by an external cooperation partner, that entity carries responsibility for the proper performance of its own service under the law and regulatory framework applicable to it. PMG’s role in coordinating such a mandate is limited to exercising reasonable care in selecting the relevant entity and properly handing over the Client’s instructions; PMG does not, without an express written undertaking, guarantee the substantive correctness of work performed outside Cyprus.
4.3 General Information Not Advice
General content PMG makes available — for example on its website, in newsletters, or in an introductory discussion — is provided for general information only and does not amount to individual legal, tax, or financial advice on the Client’s specific circumstances. A decision the Client takes on the strength of such general information alone is taken at its own risk.
4.4 No Assignment of Claims; No Class Actions
Claims against PMG may not be assigned to a third party without PMG’s prior written consent, and may not be brought as part of a class action, group action, or similar collective proceeding; each Client must pursue its own claims individually. This does not affect any right a Client has under mandatory Cyprus or EU law to participate in a collective redress mechanism that cannot lawfully be excluded by agreement.
4.5 Bank Account Applications
At the Client’s request, PMG will help prepare and submit documents for opening a bank or payment account with a Cyprus or international institution. The Client alone chooses the institution, and any recommendation PMG makes is non-binding. PMG carries out no creditworthiness check of the institution and gives no guarantee that an account application will succeed or be processed within a given time, as that decision rests solely with the institution concerned. In this regard, PMG accepts no liability for any act, omission, or breach of duty by the financial institution or fintech entity itself — including any decision to freeze, suspend, or close an account after opening — save to the extent that any resulting loss arises from PMG’s own negligence, wilful default, or fraud in preparing or submitting the application.
4.6 Responsibility of the Beneficial Owner
As set out in Section 1, the mandate exists between PMG and the beneficial owner, as entrepreneur, together with any company that owner has formed or manages through PMG. The beneficial owner is personally and jointly liable, alongside their company, for outstanding fees and other sums properly due to PMG under the mandate, unless PMG has agreed in writing to release the beneficial owner from this liability.
PMG may decline a mandate, or decline to continue acting, if it has reason to believe the true identity of a beneficial owner is being concealed, consistent with PMG’s obligations under Cyprus anti-money-laundering law.
4.7 Aggregate Cap on Liability
Subject to Section 4 above, PMG’s total aggregate liability to the Client arising out of or in connection with a given engagement, whether in contract, tort (including negligence), or otherwise, is limited to the total fees paid by the Client to PMG for the relevant service in the twelve (12) months preceding the event giving rise to the claim. This cap does not apply to any liability that cannot lawfully be limited under the law of the Republic of Cyprus.
5. Data Protection and Confidentiality
PMG processes personal data as controller (and, where relevant, processor) in accordance with the EU General Data Protection Regulation (GDPR), the Cyprus Law on the Protection of Natural Persons with Regard to the Processing of Personal Data (Law 125(I)/2018), and any other applicable Cyprus or EU data protection law. The Office of the Commissioner for Personal Data Protection of the Republic of Cyprus is the lead supervisory authority for PMG’s processing in Cyprus.
5.1 Purpose and Legal Basis
PMG processes personal data only to perform the contract, communicate with the Client, carry out commissioned work, comply with legal and regulatory obligations (including anti-money-laundering and tax reporting obligations), and process payments, and collects only the data necessary for these purposes.
Where PMG shares personal data with another group company (for example, PMG’s UAE or Irish affiliates) for the purposes of a cross-border mandate, and that transfer involves moving data outside the European Economic Area, PMG will ensure an appropriate safeguard is in place — such as the European Commission’s Standard Contractual Clauses — before the transfer takes place.
Where PMG works with an external partner or service provider, it will transfer personal data only where this is necessary for the engagement, the recipient offers an adequate level of protection, and the transfer is otherwise lawful.
5.2 Data Subject Rights
Subject to the conditions and exemptions set out in the GDPR and Cyprus law, the Client and any individual whose data PMG processes in connection with the mandate (such as a beneficial owner or director) has the right to request access to, rectification of, or erasure of their personal data, to restrict or object to its processing, to data portability, and to lodge a complaint with the Office of the Commissioner for Personal Data Protection. Where PMG is required by law to retain data for a set period (see Section 5.4), an erasure request will be actioned only once that period has expired, or to the extent erasure is possible without breaching that legal obligation.
5.3 Data Security
PMG applies appropriate technical and organisational measures to protect personal data against loss, unauthorised access, alteration, or disclosure, including encrypted data transmission, access controls and logging, and internal policies on data handling and retention.
5.4 Retention
PMG retains personal data only for as long as necessary to fulfil the purposes described above. Where a statutory retention obligation applies, PMG retains the relevant data for the applicable period even where the Client or data subject requests earlier erasure, as permitted under Article 17(3)(b) GDPR. In particular: under Cyprus anti-money-laundering law, PMG retains Client Due Diligence and transaction records for five (5) years following the Client’s last transaction, extendable if requested by a competent authority; under Cyprus tax law, PMG retains books and records relevant to the Client’s tax affairs for six (6) years from the end of the relevant tax year, or for such longer period as the Cyprus Tax Commissioner may lawfully require, including without limit of time where fraud is suspected. Where more than one retention obligation applies to the same data, PMG retains it for the longest applicable period. Data is deleted or anonymised once all applicable purposes and retention periods have expired, save where continued storage is necessary to establish, exercise, or defend a legal claim.
5.5 Confidentiality
Both parties agree to keep confidential all information received or made available to them in the course of their cooperation, whether or not expressly marked confidential, including economic, legal, tax, strategic, or personnel-related information. This obligation survives termination of the contract and ends only where the information has become public through no fault of the receiving party, must be disclosed under a statutory or regulatory duty (including to the Cyprus tax authorities, the Registrar of Companies, or PMG’s supervisory body), or needs to be disclosed to perform the contract.
6. Fees and Payment Terms
PMG provides its services on the basis of a written agreement, signed offer, or other order confirmation from the Client.
6.1 General Rules
Unless stated otherwise, all quoted fees are net of Cyprus VAT (currently charged at the applicable statutory rate where the service is subject to VAT) and of any government fee, stamp duty, or official levy payable in connection with the service. Fees are quoted and payable in euro (EUR) unless otherwise agreed in writing.
The agreed fee covers only what is set out in the offer or service description. Any extension, change, or additional service requires a separate written agreement and is billed on top, at PMG’s applicable hourly rate or an individually agreed lump sum.
Unless otherwise agreed, invoices are payable within fourteen (14) days of the invoice date. Payment is treated as made only once the full amount has been irrevocably credited to the PMG account shown on the invoice. Any bank charge, transfer fee, or currency-conversion cost is for the Client’s account, unless otherwise agreed in writing.
6.2 Accounting and Tax Services
Where PMG provides accounting, bookkeeping, annual financial statement preparation, or tax advisory services, these are provided by PMG’s internal Cyprus-licensed department. Fees are set case by case, depending on scope, corporate structure, transaction volume, and the Client’s industry-specific requirements, and are set out in the relevant offer.
6.3 Late Payment
If the Client fails to pay an invoice by its due date, PMG may charge interest on the overdue amount in accordance with the Cyprus Law on the Combating of Late Payments in Commercial Transactions (transposing EU Directive 2011/7/EU), together with reasonable compensation for recovery costs as permitted under that law, and may suspend further work until all outstanding amounts have been paid in full.
If the default continues, PMG may instruct a debt-collection agency or lawyers to recover the outstanding amount; the reasonable costs of doing so are for the Client’s account, to the extent recoverable at law.
6.4 Right of Retention
PMG may withhold documents, certificates, or other contract-related material — including completed financial statements or company documents — until all outstanding amounts have been paid in full, except where a professional or statutory rule applicable to PMG requires earlier release (for example, on a change of auditor or tax adviser under Cyprus professional rules).
6.5 One-Off and Recurring Fees
For certain services — such as registered office, compliance support, or annual company administration — PMG may charge both a one-off set-up cost and a recurring annual fee, communicated in advance and clearly identified in the offer. Ending the relationship does not release the Client from fees already incurred, or agreed, up to the date termination takes effect.
7. Term, Termination, and Renewal
7.1 Term and Renewal
The contract term is set out in the signed offer or agreement. For ongoing services — in particular registered office, accounting, tax compliance, and company administration services — a minimum term of twelve (12) months applies unless otherwise agreed.
Unless terminated in writing by either party at least two (2) months before the end of the then-current term, such a contract renews automatically for a further twelve (12) months.
7.2 Ordinary Termination
Where the specific contract allows ordinary termination, it must be given in writing, with at least two (2) months’ notice to the end of the relevant term, unless the contract specifies a different period.
7.3 Extraordinary Termination
Either party may terminate the contract for good cause with immediate effect. Good cause includes, in particular, where:
- the Client remains in payment default despite a written reminder and a reasonable opportunity to remedy;
- the Client repeatedly or materially breaches its duties of cooperation, disclosure, or documentation, including under anti-money-laundering law;
- PMG can no longer lawfully provide the contracted service, whether for regulatory, professional-conduct, or other reasons; or
- there has been a serious breach of duty that has permanently damaged the relationship of trust between the parties.
PMG may also terminate immediately if the Client knowingly provides false information, misuses a PMG address or licence, or uses PMG’s services for an unlawful purpose.
7.4 Refunds on Early Termination
Where the contract ends before the agreed services have been fully performed, PMG will refund any fee paid in advance to the extent it relates to services not yet performed and not already committed to a third party on the Client’s behalf, less any reasonable administrative cost properly incurred by PMG in winding down the engagement.
7.5 Changing Provider or Adviser
The Client may at any time appoint another service provider, tax adviser, or registered office provider. Where the Client requests such a handover, PMG will support a smooth handover — including transferring statutory books, records, and working files required by Cyprus law to be handed to a successor — and will charge a processing fee to cover the provision of necessary documents, responding to enquiries from the new provider, and exporting data.
This fee is a minimum of EUR 1,550, exclusive of VAT. Where the work involved exceeds that amount, PMG will instead charge on the basis of time actually spent, at PMG’s prevailing hourly rate, currently EUR 190 per hour, exclusive of VAT.
PMG may withhold documents until all outstanding amounts have been settled in full, save where a professional or statutory rule requires earlier release.
7.6 Data Retention after Termination
Once the contract ends, PMG will either transfer relevant documents to the Client or a nominated successor, or destroy them in accordance with data protection law, subject in either case to PMG’s own statutory retention obligations under Cyprus company, tax, and anti-money-laundering law.
8. Changes to These Terms
PMG may amend or update these Terms at any time, in particular to reflect changes in Cyprus or EU law, or to expand its range of services. PMG will notify the Client of any material change at least thirty (30) calendar days before it takes effect, in writing (including by email), together with the Client’s right to object.
If the Client does not object within that period and continues to use PMG’s services, the updated Terms apply. If the Client objects in time, the previous Terms continue to apply, and PMG may terminate the relationship on reasonable notice if continuing under the original Terms is no longer reasonable.
9. Governing Law and Jurisdiction
These Terms, and any contract or claim arising between the Client and PMG in connection with services provided under them, are governed by the law of the Republic of Cyprus.
Subject to any mandatory rule of EU or Cyprus law that provides otherwise (including, where applicable, rules on consumer jurisdiction), the courts of the Republic of Cyprus have exclusive jurisdiction over any dispute arising out of or in connection with the contractual relationship.
10. General Provisions
10.1 Severability
If any provision of these Terms is or becomes wholly or partly invalid, unenforceable, or void under Cyprus or EU law, the remaining provisions remain in force, and the invalid provision is treated as replaced by one that comes as close as legally possible to its intended effect.
10.2 Form Requirements
All agreements, amendments, and side arrangements must be made in writing (including by email), unless the law requires a stricter form.
10.3 Assignment and Transfer
The Client may not transfer or assign a right or obligation under the contractual relationship to a third party without PMG’s prior written consent. PMG may transfer this contract to an affiliated Cyprus-licensed group company carrying on the same regulated activity, provided this does not prejudice the Client’s legitimate interests, and PMG remains responsible for the proper performance of the services until any such transfer takes effect.
10.4 Language
These Terms are drafted in English. Where PMG provides a translation for convenience, the English version prevails in the event of any inconsistency, unless the parties expressly agree otherwise in writing for a specific engagement.
10.5 Tax Notice
The Client is solely responsible for meeting all tax obligations that apply to it, in Cyprus and in any other jurisdiction, regardless of nationality, residence, or place of incorporation. PMG accepts no liability for the tax consequences of any step the Client takes on the basis of general advice, recommendations, or information PMG has provided, except where PMG has expressly agreed in writing to accept responsibility for a specific, defined outcome.
PMG further notes that disclosure obligations arising under an international framework — such as the Common Reporting Standard (CRS), the EU’s DAC6 directive, or a comparable regime — remain the Client’s own responsibility, unless PMG has been expressly engaged in writing to fulfil them on the Client’s behalf.
10.6 Force Majeure
Neither party is liable for any delay or failure to perform an obligation under these Terms to the extent that the delay or failure results from an event beyond its reasonable control, including war, terrorism, civil unrest, natural disaster, epidemic or pandemic, fire, flood, act of government or regulatory authority, strike or industrial action, failure of a third-party financial institution, telecommunications, or utility provider, or failure of the Cyprus Registrar of Companies, tax authority, or other competent authority to act within its usual timeframe (a “Force Majeure Event”). The affected party will notify the other as soon as reasonably practicable and will resume performance as soon as reasonably possible once the Force Majeure Event ends.
Status: July 2026