Your Company Is Not Dormant: 100 Card Transactions Turned a €450 Quote Into €1,300

(real client enquiry)

Dear CYAUSE,

Thank you for your reply to our earlier enquiry, and apologies for coming back to you this late. We are choosing providers now and we want to know exactly what is included before we decide, so a few questions about your fees.

Some background first, so that your quote can be realistic:

• The company has been dormant since February 2026. No sales, no employees. The corporate card still pays for ten to twelve software subscriptions each month, about €430, so 2026 will end with roughly 100 to 150 card transactions. We plan to move those subscriptions to a personal card in the next month or two, so from 2027 there should be almost no movement on the account.
• The accounts show an interest-free shareholder’s current account with no fixed repayment date, €22,000 as at 31 December 2025, disclosed as a related party transaction. A further €2,000 went in during 2026.
• The subscriptions are in the director’s own name but paid by the corporate card, so most vendor invoices are not in the company’s name. We would like the auditor’s view on how to treat them.
• FY2025 was audited by our previous accountant. Those accounts carry a VAT provision on 2025 EU sales and a tax loss carried forward.
• We keep the records ourselves and file our own VAT and OSS returns through the portals. At year end we would hand over a full pack: transaction register, trial balance, bank statements with reconciliation, all invoices and minutes.

Our questions:

1. Does your €450 per year accounting and audit package for dormant companies apply to a profile like this? If not, what fixed fee would you quote for FY2026?
2. Does that fee include the tax computation and the TD4 (formerly IR4) preparation and filing? If not, how much is it?
3. The shareholder’s account, the invoices not in the company’s name, the VAT provision: are these covered by the quoted audit, or billed on top?
4. What do you charge for the audit alone, without bookkeeping?
5. Once the card activity stops, would FY2027 qualify for a review engagement instead of a full audit, and at what fee?
6. On the company secretary and registered office service at €800 per year: what is included, what does year two cost, is there a one-off transfer-in or KYC charge, and is there an exit fee?
7. Do you hold a licence for company secretarial and registered office services? If so, who issued it?

After your first reply, a few points were left so that we can compare the offers and decide. On the secretary and registered office, does the filing of the HE4 and HE2 on the transfer to you come within the €800, and are the Registrar fees included? Are the annual return HE32 and the annual UBO confirmation included? Is the signing of the documents needed for the transfer – the consent to act of the new secretary, the confirmation letter, the board resolutions – included without a separate charge? How long does the change take from signature to registration? And on the audit range you quoted, what decides whether we fall at the lower or the upper end?

Kind regards,

Dear Client,

Thank you for setting the position out so fully – it is far easier to quote against facts than against a company name. Before the individual answers, one point governs everything else in your enquiry, because it is the point that moves your fee from €450 to four figures.

1. Your company is not dormant, and that is what changes the price

“Dormant” is not a description of how busy you feel. For the purposes of a fixed low-cost tariff it means nil activity in the financial year and no movement on the balance sheet – no transactions to record, nothing to reconcile, nothing to substantiate.

Your FY2026 has, on your own figures, between 100 and 150 card transactions, an operating cost running at roughly €430 a month, and a shareholder’s current account that moved by €2,000 during the year. Every one of those transactions has to be recorded, classified, agreed to the bank and supported. That is an ordinary small audit, not a dormant filing, and the €450 tariff does not reach it.

This is the single most common misunderstanding we see. A company with no customers is still a trading company for accounting purposes if it is spending money. The trigger is activity, not revenue.

2. Indicative fees for your profile

Indicative only, for the facts described in this enquiry. A firm quote follows the prior-year audited financial statements, the turnover and a description of the activity.

3. What the fee includes – tax computation, TD4 and the awkward items

The tax computation and the preparation and filing of the corporate income tax return (form TD4, previously known as the IR4) are included in the quoted accounting and audit fee. They are not billed separately.

So are the three items you flagged. The interest-free shareholder’s current account with no fixed repayment date is a related party balance that needs disclosure and a recoverability view, not an extra engagement. The vendor invoices in the director’s personal name, paid by the company card, are an ordinary substance-over-form question: the audit work is to establish that the subscriptions are incurred wholly and exclusively for the company’s business, and to document that conclusion, and the practical fix is to move the accounts into the company’s name so that the point does not recur. The VAT provision carried forward from FY2025 is reviewed as part of the audit. None of these is charged on top.

On your question about where in the €800 to €1,200 range an audit-only engagement lands: it is decided by the quality of the accounting records, not by their volume. Where the books have been kept by the owner rather than by an accountant, more audit time goes on reclassifying expenses and chasing support, which pushes the fee towards the upper end. The handover pack you describe – transaction register, trial balance, reconciled bank statements, all invoices and minutes – is exactly what keeps a fee at the lower end.

One timing point worth noting: for tax year 2026 onwards the TD4 filing deadline moves to 31 January of the second year following the tax year, so a 31 December 2026 year end is due by 31 January 2028. Up to and including tax year 2025 the deadline was 31 March of the second year following, subject to the transitional decrees that have varied particular years.

4. The bigger saving is not the fee – it is replacing the audit with a review

You asked whether FY2027 could qualify for a review engagement once the card activity stops. It is the right question, and it is worth more than any discount on the audit fee. But the test is not whether the card is quiet. A Cyprus company may replace its statutory audit with a review engagement where its net turnover and its total gross assets are both below the statutory thresholds for two consecutive financial years.

Sources: the Companies Law, Cap. 113, as amended, and the thresholds in force for financial years beginning on or after 6 February 2026. See the Registrar of Companies at companies.gov.cy and our own note, Audit Threshold Increased to €300,000.

Applied to you: a company with no sales and a small balance sheet is already inside both limits, so the constraint is the two-consecutive-year condition and the state of the FY2025 comparatives, not the card. That is the analysis to run once the FY2025 statements are in front of us – it may well bring FY2027 within a review, and on the figures you describe it is worth looking at FY2026 as well. We would not want to promise the outcome before seeing the prior-year accounts.

One caution. A review gives limited assurance only. If you expect to need bank finance, to sell the company, or to satisfy a counterparty’s due diligence, an audit report is the document that will be asked for, and the saving is a false economy.

5. Company secretary and registered office – what the €800 buys

• Provision of the registered office address, and the receipt, scanning or forwarding of incoming statutory mail.
• Maintenance of the statutory registers and minute book, and the filing of documents on your instruction.
• The annual return, form HE32, and the annual confirmation of the beneficial ownership register.
• The transfer-in filings themselves – the HE4 and HE2 for the change of secretary and change of registered office – together with the consent to act, the confirmation letter and the board resolutions. There is no separate signing charge for these documents.
• Registrar filing fees and other disbursements are charged at cost and sit outside the €800.

On timing: from signature of the documents to registration at the Registrar generally takes a few weeks, depending on the Registrar’s workload at the time. It is not a same-day process, and a firm that promises one is describing the submission, not the registration.

Year two is charged at the same annual rate. Where the file proves genuinely light in practice, we can look at the renewal again with you. On the one-off transfer-in and KYC charge of €400, we can often waive or reduce it where the company is a small operation and the incoming file is clean. We do not operate an exit fee; if a future handover involves substantial correspondence with an incoming provider, that time may be charged, but in most cases nothing arises.

The beneficial ownership point deserves a line of its own, because it is the one that catches dormant companies. The annual confirmation window runs from 1 October to 31 December each year, and it must be completed even where nothing has changed. Late filing attracts €100 on the first day and €50 for each day thereafter, capped at €5,000 – a penalty that can comfortably exceed the annual fee of the company it is levied on. Details are published by the Registrar of Companies.

6. The licence question – and why you were right to ask it

Yes. Company secretarial and registered office services are administrative services, and in Cyprus they may only be provided by a licensed administrative service provider. There are three supervisory authorities: the Institute of Certified Public Accountants of Cyprus (ICPAC), the Cyprus Bar Association, and the Cyprus Securities and Exchange Commission. Our corporate and secretarial services are delivered through an affiliated regulated practice licensed by the Cyprus Bar Association, and our audit and accounting work is carried out by our ICPAC-regulated audit firm.

Very few prospective clients ask this question, and it is the one that most deserves asking. An unlicensed provider is a compliance exposure for you, not only for them – and it is worth asking any competing quote the same question before comparing prices.

7. What we would suggest

Budget for FY2026 on the basis of an ordinary small audit rather than a dormant filing; the €450 tariff is not available on these facts and no provider who understands the file should quote it. Move the software subscriptions into the company’s name rather than simply onto a personal card, so that the invoice-in-the-wrong-name point disappears instead of migrating. Send us the FY2025 audited financial statements so that we can test the review-engagement route properly, for FY2026 as well as FY2027. And note that a company that stops trading is not thereby a company that stops filing: the TD4, the HE32 and the beneficial ownership confirmation all continue.

Kind regards,

This article is based on a real client enquiry, published with identifying details removed. It is general information only and is not investment, tax, legal or audit advice. The fees quoted are indicative, relate to one specific set of facts, and do not constitute an offer. Thresholds, deadlines and penalties change; confirm the position that applies to your own circumstances before acting. To discuss your company, write to enquiries@cyprusaccountants.com.cy or call +357 22 336 309.