Wealth & Estate

Founder Relocation

Personal relocation to Cyprus aligned with the corporate structure and the exit plan.

Overview

For a founder-led business, the personal and corporate positions are examined together. A Cyprus company whose sole decision-maker lives and works in another country is a Cyprus company directed from that country, and appointing local directors does not change where the decisions are visibly made.

That makes relocation the step that resolves the corporate question as well as the personal one. When the founder moves, management and control move with them, and the substance position becomes straightforward rather than argued.

The work spans three things that are usually handled by different people and rarely coordinated: the personal residency and domicile position, the corporate governance that follows from it, and the practical business of actually moving, including the departure jurisdiction's view of the exit.

What is included

  • Residency route selection modelled against intended travel and family circumstances
  • The non-domiciled claim, and modelling of the 17 of 20 year horizon
  • Departure jurisdiction analysis: exit charges, deemed disposals, trailing residence rules, and the treaty tie-breaker position
  • Employment structuring where the founder will be employed by the Cyprus company, including eligibility for the 50 percent and 25 percent income exemptions
  • Corporate governance realignment so the board and decision-making move on the same timeline
  • Permanent residence arrangements, whether purchased or leased, on terms that satisfy the 60-day rule
  • Registration with the Tax Department, social insurance and the health system
  • Banking, both personal and corporate, with the supporting documentation prepared in advance
  • Day-count records and the contemporaneous evidence file
  • Coordination with immigration advisers where a permit is required

How Doviandi approaches this

Sequencing comes before structuring. Both residency routes are measured across a calendar year, so the first question is which year the move lands in and what that means for any transaction in view. A relocation begun in the autumn is a relocation for the following tax year.

The departure analysis is the first deliverable. The country being left decides most of the risk. Exit charges and trailing rules can make a move expensive or, in the year of a sale, ineffective, and that has to be established before anything is committed.

Corporate and personal move together. We align the board changes, the governance calendar and the founder's arrival so the company's management and control shift on a single, evidenced timeline rather than drifting over two years.

Family circumstances are treated as facts, not details. Where a spouse remains abroad or children stay in school elsewhere, the centre of vital interests analysis changes and the treaty tie-breaker may not resolve as expected. We raise that early because it is the point on which otherwise sound relocations fail.

Background reading on the questions this service answers:

Engagement at a glance
Personal residency routesMore than 183 days, or the 60-day rule on four conditions
Corporate consequenceWhere the founder decides, the founder's location shapes management and control
Timing constraintBoth are measured over the calendar year and cannot be created retrospectively
Departure riskExit charges, deemed disposals and trailing residence rules
Dividend position once resident and non-domiciledNo Special Defence Contribution, GESY still applies
Employment income exemptions50 percent above 55,000, or 25 percent capped at 25,000 above 30,000

Ready to design your Cyprus structure?

Book a confidential consultation with Doviandi. We will review your corporate, IP, and residency position against the 2026 Cyprus tax framework.