Industry
Private clients relocating wealth, structuring succession, or consolidating a family office.
16 pages
Comparison
A share sale is the standard route and is ordinarily outside Cyprus tax. From 2026, disposing of shares attracts 20 percent capital gains tax where at least 20 percent of the company's asset value derives from Cyprus immovable property. On an asset sale, IP disposed of as a capital asset is generally exempt.
Entity
A Cyprus International Trust is a trust where the settlor and beneficiaries are not Cyprus tax residents in the year before establishment and at least one trustee is resident in Cyprus throughout. It carries strong statutory protection against foreign forced heirship and a long challenge window.
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
The 2026 reform abolished the Special Defence Contribution on rental income. What remains is income tax for an individual or corporate income tax at 15 percent for a company, in both cases after a statutory 20 percent deduction on gross rents and the deductible expenses.
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.
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.
Guide
Selling the shares of a Cyprus company produces no Cyprus tax on the gain, subject to the property test. On an asset sale, intellectual property disposed of as a capital asset is generally exempt, while a disposal forming part of the company's recurring trade is charged to corporate tax at 15 percent.
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
A Cyprus holding company receives most foreign dividends free of Cyprus tax under the participation exemption, pays no withholding tax on dividends out to non-residents, and is exempt on gains from disposing of shares. The combination makes it efficient at holding subsidiaries and at receiving a sale price.
Decision
For a Cyprus company, foreign dividends are exempt in most cases under the participation exemption, and are charged only where the payer is predominantly passive and taxed below 7.5 percent. For an individual, the answer turns on domicile rather than on the source of the dividend.
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.
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.
