Industry
Founders relocating themselves and their company, and location-independent professionals establishing a residency position.
33 pages
Entity
Yes. A Cyprus company may be wholly owned by non-residents, with no nationality restriction, no local shareholder requirement and no minimum capital of consequence. What non-residents cannot avoid is beneficial ownership disclosure and the anti-money-laundering file that precedes incorporation.
Guide
A founder taking a salary from their own Cyprus company runs payroll like any employer: income tax withheld at source, social insurance from both employee and employer, and GESY. The salary supports the residency position and builds a contribution record that dividends do not.
Guide
Regulation 6(2) grants permanent residence on a qualifying investment of 300,000 euro plus VAT, supported by secured annual income from abroad of at least 50,000 euro. The permit does not expire, and it does not make the holder Cyprus tax resident.
Guide
A residence permit gives permission to live in Cyprus. Tax residency decides which country taxes you. They are granted by different authorities under different tests, and the permit that lets you stay can be the one that blocks the 60-day route to tax residency.
Playbook
A tax residency certificate is issued by the Cyprus Tax Department confirming that a person or company was tax resident here for a stated year. It is the document a foreign payer, bank or tax authority asks for before applying treaty rates, and it is issued for a year, not indefinitely.
Decision
Timing decides the outcome. Cyprus exempts gains on the disposal of securities and charges no Special Defence Contribution on dividends for a non-domiciled resident. Both depend on residency being established before the disposal, and on the departure jurisdiction not retaining a claim.
Playbook
CGT event I1 treats assets that are not taxable Australian property as disposed of at market value when residence ceases, with an all-or-nothing election to defer. Australia and Cyprus have no double tax treaty in force, which removes the tie-breaker every other playbook in this set relies on.
Playbook
France charges unrealised gains on departure where holdings exceed 800,000 euro or represent more than 50 percent of a company. Because Cyprus is an EU member state, deferral of payment is ordinarily available rather than immediate collection, which changes the arithmetic substantially.
Playbook
Germany is the most consequential departure in this set. Section 6 of the Aussensteuergesetz treats a shareholding of at least 1 percent as sold at market value when unlimited tax liability ends, so the charge falls on unrealised value in the company rather than on anything received.
Playbook
India levies no exit charge, and residence turns on day count with a transitional resident but not ordinarily resident tier. The constraints that actually bind an Indian founder are exchange control under FEMA and the place of effective management test applied to the Cyprus company.
Playbook
Israel treats assets as sold the day before residence ceases under section 100A, with the option to defer the charge to actual disposal and apportion the gain by holding period. Residence itself is decided by the centre of life test, which weighs facts rather than counting days.
Playbook
Italy redefined tax residence with effect from 2024, so registration in the resident population register is now a rebuttable presumption rather than the decisive fact. Deregistering and registering with AIRE remains necessary, and it is where Italian departures most often go wrong.
Playbook
Lithuania levies no exit charge on individuals. Residence is decided by a set of alternative tests, any one of which is sufficient, and the one that catches founders is the location of personal, social or economic interests rather than the day count.
Playbook
New Zealand residence ends only when there is no permanent place of abode and the individual has been absent for more than 325 days in a 12-month period. Both limbs must be satisfied, and a retained house can defeat the first indefinitely. There is no treaty with Cyprus.
Playbook
Norway charges unrealised gains on shares when tax residence ends, and the rules were tightened with effect from 2024 and 2025. The deferral that was once open ended now runs to a limit, so the charge can fall due even if the shares are never sold.
Playbook
Poland introduced exit taxation in 2019 when implementing the EU anti-tax avoidance directive. It reaches assets above 4 million zloty at 19 percent, or 3 percent where the tax base cannot be determined. Below that threshold the charge does not apply, and the centre of interests test still does.
Playbook
Section 9H deems a disposal of worldwide assets, excluding South African immovable property, on the day before residence ceases. Cessation is notified to SARS rather than assumed, and financial emigration stopped being the route for this in March 2021.
Playbook
Spain charges unrealised gains on departure only above high thresholds, reached where the individual was resident for 10 of the previous 15 years and holds shares above 4 million euro, or above 1 million euro with a stake of at least 25 percent. Moving within the EU ordinarily allows deferral.
Playbook
Sweden has no departure charge. It keeps a claim instead, taxing capital gains on securities for up to ten calendar years after you leave, and it presumes continued residence through an essential connection test that places the burden of proof on the individual.
Playbook
Switzerland levies no exit tax on individuals. Liability ends on deregistration with the commune, alongside a final return covering income to the date of departure. The questions that remain are pension capital and reclaiming Swiss withholding tax.
Playbook
A holding of at least 5 percent in a company is a substantial interest, and emigration triggers a conserverende aanslag, a protective assessment on the unrealised gain. It is issued rather than collected at departure, which is what makes it easy to overlook and expensive to rediscover.
Playbook
The UK charges nothing on departure itself. What decides the outcome is breaking residence under the Statutory Residence Test, avoiding the five-year temporary non-residence claw-back, and understanding that the April 2025 reforms replaced domicile with long-term residence for inheritance tax.
Playbook
The United States taxes citizens and green card holders on worldwide income wherever they live, so moving to Cyprus does not change the US tax base at all. There is no charge on leaving. The exit tax arises only on formally giving up citizenship or long-term resident status as a covered expatriate.
Playbook
Ukraine levies no exit tax. Residence is decided by a hierarchy that starts with domicile, moves to the centre of vital interests, then to day count and finally to citizenship, and the practical difficulty is evidencing that the centre of vital interests moved. Currency controls govern moving capital.
Playbook
Account opening is a second, independent review after the provider's own due diligence, and it is normally the longest step in setting up a Cyprus company. What decides the timetable is the quality of the file rather than the size of the deposit.
Guide
Source of funds is where the specific money came from. Source of wealth is how the overall wealth was built. A licensed Cyprus provider must document both before acting, and confusing the two is the single most common reason an onboarding stalls.
Decision
Only on their own facts. Domicile is personal and is not shared between spouses, so each individual is assessed separately on their domicile of origin and their own residence history. One spouse can be non-domiciled while the other is deemed domiciled.
Entity
An individual who spends more than 183 days in Cyprus in a calendar year is Cyprus tax resident. No other condition applies. It is the simpler of the two routes to residency, and unlike the 60-day rule it requires no Cyprus tie, no permanent home and no limit on days spent elsewhere.
Entity
The 60-day rule makes an individual Cyprus tax resident on 60 days of presence rather than 183, if four conditions are met. From 1 January 2026 the former requirement not to be tax resident elsewhere was removed, so the rule now has four conditions rather than five.
Entity
Cyprus non-domiciled status exempts a Cyprus tax resident from Special Defence Contribution on dividends and interest. It applies to individuals whose domicile of origin is outside Cyprus and who have not been resident for 17 of the previous 20 years. It does not remove the GESY health contribution.
Comparison
Dubai offers a lower headline rate. Cyprus offers EU membership, the participation exemption, an extensive treaty network and directive access. For a founder selling into Europe or raising from European investors, market access and treaty relief usually decide the answer before the rate does.
Decision
Until you have been Cyprus tax resident for 17 of the previous 20 tax years, at which point you are deemed Cyprus domiciled and Special Defence Contribution begins to apply. From 1 January 2026 a person with a foreign domicile of origin may extend the status by up to two further five-year periods for a lump sum.
Playbook
Choose a route, either more than 183 days in Cyprus or the four conditions of the 60-day rule, then establish the facts before the tax year begins rather than during it. Register with the Tax Department, obtain a tax identification number, and claim non-domiciled status separately.
Services
Incorporation of a Cyprus limited company, from name approval to tax registration.
Holding structures using the participation exemption and Cyprus treaty network.
Transfer of an existing foreign company into Cyprus without breaking legal continuity.
Management and control, governance and the evidence file that supports tax residency.
Bring the facts you have. We will map the structural options, what each one requires, and the point at which the trade-offs actually bite.
