The headline rate has not moved, but the rules around it have. Substance is no longer a checkbox: tax authorities and counterparties look at real decision-making, real costs, and people on the ground.
We see three patterns continuing to work well: regional IP holding for groups with genuine R&D presence in Cyprus, financing companies inside larger groups with clear arm's-length pricing, and pure equity holding tied to operational subsidiaries in the EU.
Where we caution clients is on light-touch structures created purely for treaty access. The cost of getting it wrong now exceeds any benefit.