22 pages
Ordered execution sequences. What happens first, what it depends on, and what evidence each step produces.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Redomiciliation moves an existing company into Cyprus while preserving its legal identity, so contracts, bank accounts and intellectual property stay with the same entity. It requires that the departing jurisdiction permits it and that the company's own constitution allows it.
Book a confidential consultation with Doviandi. We will review your corporate, IP, and residency position against the 2026 Cyprus tax framework.
