# Doviandi > Doviandi advises international founders, technology companies and private clients on Cyprus corporate structuring, intellectual property and relocation, including IP Box qualification, economic substance, non-domiciled tax residency and licensed administrative service provider work. Doviandi is a Cyprus corporate, fiduciary and relocation advisory firm based at 16 Charalampou Kalaitzi, 2015 Nicosia, Cyprus, advising international clients since 2014. Technical positions are written and reviewed by Chris Parpas, Managing Director, BFP FCA ICPAC. ## How to read this site - Every knowledge page opens with a short answer of 60 words or fewer, stating the position directly. - Every page carries a last-reviewed date. Treat any figure without one as unverified. - Factual claims cite Cyprus legislation, the Cyprus Tax Department, OECD instruments or EU directives. Competitor sources are never cited. - Where a position depends on facts not stated, the page says what it depends on rather than asserting an answer. - Corrective note: the Cyprus IP Box effective rate at full nexus is 3 percent following the 2026 corporate tax reform, which raised the headline rate to 15 percent. The widely repeated 2.5 percent figure reflects the pre-2026 12.5 percent rate and is out of date. ## Entities Canonical definitions of the terms that appear across Cyprus structuring work. One term, one page, one authoritative answer. - [Administrative Service Provider](https://doviandi.com/knowledge/entities/administrative-service-provider/): An administrative service provider is a firm licensed and supervised in Cyprus to incorporate and administer companies, provide registered office and directors, act as nominee shareholder and manage trusts. The licence carries anti-money laundering obligations, and providing these services without one is a regulatory offence. (reviewed 2026-08-06) - [Can Foreigners Own a Cyprus Company?](https://doviandi.com/knowledge/entities/can-foreigners-own-cyprus-companies/): 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. (reviewed 2026-08-07) - [Controlled Foreign Company Rules](https://doviandi.com/knowledge/entities/controlled-foreign-company/): Controlled foreign company rules attribute the undistributed income of a low-taxed foreign subsidiary back to its controlling parent, taxing it before any dividend is paid. Cyprus applies them under the EU anti-tax avoidance directive, and so does every other member state. (reviewed 2026-08-07) - [Cyprus 183-Day Rule](https://doviandi.com/knowledge/entities/cyprus-183-day-rule/): 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. (reviewed 2026-08-06) - [Cyprus 60-Day Rule](https://doviandi.com/knowledge/entities/cyprus-60-day-rule/): 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. (reviewed 2026-08-06) - [Cyprus Alternative Investment Fund](https://doviandi.com/knowledge/entities/cyprus-alternative-investment-fund/): A Cyprus Alternative Investment Fund is a collective investment vehicle authorised and supervised by CySEC. Three forms exist: the AIF, the AIF with a limited number of persons, and the registered AIF, which is not itself authorised but must be managed by an authorised manager. (reviewed 2026-08-07) - [Cyprus International Trust](https://doviandi.com/knowledge/entities/cyprus-international-trust/): 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. (reviewed 2026-08-07) - [Cyprus IP Box](https://doviandi.com/knowledge/entities/cyprus-ip-box/): The Cyprus IP Box gives an 80 percent notional deduction on qualifying profit from qualifying intangible assets, principally patents and copyrighted software. The benefit is limited by the OECD modified nexus fraction, so it tracks the research the company itself funded. At the 15 percent corporate rate applying from 2026, the effective rate at full nexus is 3 percent. (reviewed 2026-08-06) - [Cyprus Non-Dom Status](https://doviandi.com/knowledge/entities/cyprus-non-dom-status/): 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. (reviewed 2026-08-06) - [Cyprus Tonnage Tax](https://doviandi.com/knowledge/entities/cyprus-tonnage-tax/): The Cyprus tonnage tax system charges qualifying shipowners, charterers and ship managers by reference to the net tonnage of their vessels rather than on profit. It is an EU-approved regime, and electing into it replaces corporate income tax on qualifying shipping activities. (reviewed 2026-08-07) - [Deemed Dividend Distribution](https://doviandi.com/knowledge/entities/deemed-dividend-distribution/): The deemed dividend distribution rules treated a proportion of undistributed profits as though they had been paid out, triggering Special Defence Contribution. The 2026 reform abolished them for profits earned from 1 January 2026, while 2024 and 2025 profits remain within them until 31 December 2027. (reviewed 2026-08-07) - [Economic Substance](https://doviandi.com/knowledge/entities/economic-substance/): Economic substance is the evidence that a Cyprus company is genuinely managed and controlled in Cyprus rather than administered from elsewhere. Cyprus applies a management and control test for corporate tax residency. Substance is proportionate to the business, so there is no fixed headcount or office size that satisfies it. (reviewed 2026-08-06) - [GESY](https://doviandi.com/knowledge/entities/gesy/): GESY is the Cyprus General Healthcare System, funded by contributions from employees, employers, the self-employed and holders of other income including dividends and rent. Contributions are levied on income up to an annual cap of 180,000 euro across all sources combined. (reviewed 2026-08-07) - [Nominee Director](https://doviandi.com/knowledge/entities/nominee-director/): A nominee director is a director appointed by a licensed provider to sit on a company's board. The role carries the full legal duties of a director, including the duty to exercise independent judgement, so a nominee can decline to act on an instruction that would breach those duties. (reviewed 2026-08-06) - [Notional Interest Deduction](https://doviandi.com/knowledge/entities/notional-interest-deduction/): The notional interest deduction allows a Cyprus company to deduct a notional return on new equity introduced from 2015 onwards, capped at 80 percent of the taxable profit generated by that equity. It puts equity funding closer to debt funding, which is deductible. (reviewed 2026-08-07) - [Participation Exemption](https://doviandi.com/knowledge/entities/participation-exemption/): The participation exemption removes foreign dividends received by a Cyprus company from Cyprus tax in most cases. It applies unless the paying company is more than half engaged in investment activity and is taxed at an effective rate significantly below the Cyprus burden, a threshold set at 7.5 percent from 2026. (reviewed 2026-08-06) - [Permanent Establishment](https://doviandi.com/knowledge/entities/permanent-establishment/): A permanent establishment is a taxable presence a company creates in another country, either through a fixed place of business or through a dependent agent who habitually concludes contracts there. It is created by people and places, not by where customers are located. (reviewed 2026-08-07) - [Special Defence Contribution](https://doviandi.com/knowledge/entities/special-defence-contribution/): The Special Defence Contribution is a Cyprus tax on dividends and interest, separate from income tax. It applies only to individuals who are both Cyprus tax resident and domiciled in Cyprus. Non-domiciled residents are outside it entirely, which is what non-dom status delivers. (reviewed 2026-08-07) - [Transfer Pricing in Cyprus](https://doviandi.com/knowledge/entities/cyprus-transfer-pricing/): Transfer pricing rules require transactions between related parties to be priced as unrelated parties would price them, and documented. Cyprus operates a formal regime with local file thresholds of 5 million euro for goods, 10 million for financing and 2.5 million for other categories from 2026. (reviewed 2026-08-07) ## Guides Long-form treatments of a regime end to end: what it is, how it is applied, and where it breaks down in practice. - [Cyprus Economic Substance: A Comprehensive Guide for International Companies (2025/2026)](https://doviandi.com/cyprus-economic-substance-guide/): Economic substance determines whether a Cyprus company secures tax residency and treaty access. Cyprus applies a management and control test, and the level of substance required scales with the business model, sector and cross-border footprint rather than following a fixed checklist. (reviewed 2026-05-12) - [Cyprus IP Box: Definitive Guide for SaaS, AI & Technology Companies (2026)](https://doviandi.com/cyprus-ip-box-guide/): The Cyprus IP Box gives up to an 80 percent notional deduction on qualifying profits from qualifying intellectual property, built on the OECD Modified Nexus Approach. Availability depends on real research activity, operational substance, documentation and the relationship between the IP owner and the underlying development functions. (reviewed 2026-05-17) - [Cyprus Payroll and Social Insurance for Company Officers](https://doviandi.com/knowledge/guides/cyprus-payroll-and-social-insurance/): 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. (reviewed 2026-08-07) - [Cyprus Permanent Residency by Investment](https://doviandi.com/knowledge/guides/cyprus-permanent-residency-by-investment/): 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. (reviewed 2026-08-07) - [Cyprus Residence Permits and Tax Residency](https://doviandi.com/knowledge/guides/cyprus-residence-permits-and-tax-residency/): 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. (reviewed 2026-08-07) - [Cyprus SaaS and AI Company Structure (2026 Operational Framework)](https://doviandi.com/cyprus-saas-and-ai-company/): Operating a Cyprus SaaS or AI company involves more than incorporation or access to the IP Box. Qualification depends on the interaction between ownership, development activity, expenditure classification, and management and control over time, assessed across personal, corporate and functional layers. (reviewed 2026-06-28) - [Cyprus VAT: Registration, Thresholds and Place of Supply](https://doviandi.com/knowledge/guides/cyprus-vat-registration-and-thresholds/): Registration is compulsory once taxable supplies exceed 15,600 euro in any 12 months. The standard rate is 19 percent, with reduced rates of 9 and 5 percent, and a zero rate. What decides whether Cyprus VAT applies at all is the place of supply rather than where the company sits. (reviewed 2026-08-07) - [How Qualifying Profit Is Calculated Under the Cyprus IP Box](https://doviandi.com/knowledge/guides/how-qualifying-profit-is-calculated/): Overall income from the asset is multiplied by the nexus fraction to give qualifying profit. The fraction is qualifying expenditure plus uplift, divided by overall expenditure, capped at one. Eighty percent of qualifying profit is then deducted, and the remainder is taxed at 15 percent. (reviewed 2026-08-06) - [Rental Income Tax in Cyprus After the 2026 Reform](https://doviandi.com/knowledge/guides/cyprus-rental-income-tax/): 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. (reviewed 2026-08-07) - [Selling a Cyprus Company: Tax Implications](https://doviandi.com/knowledge/guides/selling-a-cyprus-company/): 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. (reviewed 2026-08-07) - [Source of Funds and Source of Wealth](https://doviandi.com/knowledge/guides/source-of-funds-and-source-of-wealth/): 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. (reviewed 2026-08-07) - [The Cyprus Company Compliance Calendar](https://doviandi.com/knowledge/guides/cyprus-company-compliance-calendar/): A Cyprus company files an annual return with the Registrar, an income tax return with audited financial statements, and VAT and payroll returns where registered. The obligations sit with two different authorities on two different timetables, which is why one is so often missed. (reviewed 2026-08-07) ## Decisions The judgement calls founders actually face, with the conditions that push the answer one way or the other. - [Are Foreign Dividends Taxable in Cyprus?](https://doviandi.com/knowledge/decisions/are-foreign-dividends-taxable-in-cyprus/): 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. (reviewed 2026-08-06) - [Best EU Country for a SaaS Company](https://doviandi.com/knowledge/decisions/best-eu-country-for-saas/): There is no single answer, because the deciding variable is where the engineering is funded rather than which rate is lowest. Cyprus, Ireland, Estonia and the Netherlands each win under different conditions, and the choice should follow the team and the customers. (reviewed 2026-08-06) - [Can a Foreign Company Use the Cyprus IP Box?](https://doviandi.com/knowledge/decisions/can-foreign-companies-use-cyprus-ip-box/): Not directly. The deduction is available to a company that is tax resident in Cyprus, which turns on management and control rather than on incorporation. A foreign-incorporated company can access it only by becoming Cyprus tax resident, redomiciling, or transferring the asset into a Cyprus entity. (reviewed 2026-08-07) - [Can Directors of a Cyprus Company Live Abroad?](https://doviandi.com/knowledge/decisions/can-directors-live-abroad/): There is no legal requirement for a Cyprus company's directors to be resident in Cyprus. But corporate tax residency follows incorporation in Cyprus or management and control exercised in Cyprus, and where another country also claims the company it is management and control that decides. A board that meets and decides abroad is the clearest way to fail that test. (reviewed 2026-08-07) - [Can My Spouse Qualify for Cyprus Non-Dom Status?](https://doviandi.com/knowledge/decisions/can-spouse-qualify-for-non-dom/): 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. (reviewed 2026-08-06) - [Do Machine Learning Models Qualify for the Cyprus IP Box?](https://doviandi.com/knowledge/decisions/do-machine-learning-models-qualify/): A model can qualify where it rests on a legally protected asset, most often copyright in the training and inference code, and where the company funded the development. Trained weights alone sit on weaker ground than the code that produces them, so the claim is usually built around the system rather than the model file. (reviewed 2026-08-06) - [Does software qualify for the Cyprus IP Box?](https://doviandi.com/knowledge/decisions/does-software-qualify-for-ip-box/): Yes. Copyrighted software is a qualifying intangible asset, so a Cyprus company licensing or embedding its own software can claim the 80 percent deduction. Whether meaningful benefit follows depends on the nexus fraction, which measures how much of the development the company funded itself rather than acquiring from a related party. (reviewed 2026-08-06) - [Does the Cyprus IP Box Require Economic Substance?](https://doviandi.com/knowledge/decisions/does-ip-box-require-substance/): Yes, and in two separate ways. The company must be Cyprus tax resident on the management and control test, and the nexus fraction independently requires that the company funded the development itself. Satisfying one does not satisfy the other. (reviewed 2026-08-06) - [How Long Does Cyprus Non-Dom Status Last?](https://doviandi.com/knowledge/decisions/how-long-does-non-dom-last/): 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. (reviewed 2026-08-06) - [How Many Employees Does a Cyprus Company Need for Substance?](https://doviandi.com/knowledge/decisions/how-many-employees-for-substance/): There is no statutory number. Cyprus applies a management and control test rather than a headcount test, so what is required scales with the activity, the value carried and the relief being claimed. A passive holding company and an operating software business are not asked for the same thing. (reviewed 2026-08-07) - [How to Choose a Cyprus ASP](https://doviandi.com/knowledge/decisions/how-to-choose-a-cyprus-asp/): Start by confirming the licence, because providing company administration and directorships in Cyprus is a regulated activity. After that the questions that separate providers are who signs, what happens when they disagree with you, and what the fee actually includes. (reviewed 2026-08-07) - [Nominee Director or Power of Attorney?](https://doviandi.com/knowledge/decisions/nominee-director-or-power-of-attorney/): A nominee director sits on the board and owes duties to the company. A power of attorney authorises someone to act on your behalf and creates no board seat. They solve different problems, and using a power of attorney to run a company from abroad undermines the management and control position. (reviewed 2026-08-07) - [Should I Move to Cyprus Before Selling My Company?](https://doviandi.com/knowledge/decisions/move-to-cyprus-before-selling/): 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. (reviewed 2026-08-07) - [Should IP Be Owned by a Holding Company?](https://doviandi.com/knowledge/decisions/should-ip-be-owned-by-holding-company/): Yes, and for most software groups it is the preferred structure. A Cyprus IP holding company owns the code and licenses it to an operating company for a royalty. The nexus fraction is maintained by having the IP company itself fund the development, through its own staff or unrelated contractors. (reviewed 2026-08-07) - [The Drawbacks of a Cyprus Company](https://doviandi.com/knowledge/decisions/drawbacks-of-a-cyprus-company/): The real costs are an annual assurance engagement, a banking process measured in weeks, substance that has to be genuine and paid for, and the fact that none of the advantages reach a founder who stays tax resident somewhere else. (reviewed 2026-08-07) - [Where Should a Founder Own Software IP?](https://doviandi.com/knowledge/decisions/where-to-own-software-ip/): The company that funds the development should own the code. Ownership split from funding produces a weak nexus fraction, a transfer pricing problem and an assignment gap at diligence. Deciding this before the spending starts is worth more than any restructuring afterwards. (reviewed 2026-08-07) - [Why Use a Cyprus Holding Company?](https://doviandi.com/knowledge/decisions/why-use-a-cyprus-holding-company/): 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. (reviewed 2026-08-07) - [Why Use an ASP Instead of Incorporating Yourself?](https://doviandi.com/knowledge/decisions/why-use-an-asp/): Incorporation is the cheapest part of a Cyprus structure and the least consequential. A licensed provider supplies the registered office, resident directors, statutory records and filings that the residency position depends on, and several of those services may only be provided under a licence. (reviewed 2026-08-06) ## Comparisons Jurisdiction and structure comparisons written in strict parallel so each dimension can be read across. - [Asset Sale or Share Sale in Cyprus](https://doviandi.com/knowledge/comparisons/asset-sale-vs-share-sale/): 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. (reviewed 2026-08-07) - [Cyprus or Dubai: Choosing Between an EU and a Gulf Structure](https://doviandi.com/knowledge/comparisons/cyprus-vs-dubai/): 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. (reviewed 2026-08-06) - [Cyprus or Ireland for Corporate Tax](https://doviandi.com/knowledge/comparisons/cyprus-vs-ireland/): Ireland charges 12.5 percent on trading income and Cyprus 15 percent from 2026, so Ireland leads on headline rate. Cyprus leads on the treatment of what leaves the company: no withholding tax on outbound dividends to non-residents, and no Special Defence Contribution for a non-domiciled resident shareholder. (reviewed 2026-08-06) - [Cyprus or Malta: Two EU Routes to a Similar Outcome](https://doviandi.com/knowledge/comparisons/cyprus-vs-malta/): Both are EU members with English-language legal systems and strong treaty networks. Cyprus taxes corporate profit at 15 percent directly. Malta charges 35 percent and refunds part of it to shareholders on distribution, which reaches a comparable place through a two-company structure and a refund cycle. (reviewed 2026-08-06) ## Playbooks Ordered execution sequences. What happens first, what it depends on, and what evidence each step produces. - [How to Become Cyprus Tax Resident](https://doviandi.com/knowledge/playbooks/how-to-become-cyprus-tax-resident/): 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. (reviewed 2026-08-06) - [How to Obtain a Cyprus Tax Residency Certificate](https://doviandi.com/knowledge/playbooks/cyprus-tax-residency-certificate/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Australia](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-australia/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from France](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-france/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Germany](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-germany/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from India](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-india/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Israel](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-israel/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Italy](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-italy/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Lithuania](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-lithuania/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from New Zealand](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-new-zealand/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Norway](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-norway/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Poland](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-poland/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from South Africa](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-south-africa/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Spain](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-spain/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Sweden](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-sweden/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Switzerland](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-switzerland/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from the Netherlands](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-the-netherlands/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from the UK](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-the-uk/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from the USA](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-the-usa/): 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. (reviewed 2026-08-07) - [Moving to Cyprus from Ukraine](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-ukraine/): 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. (reviewed 2026-08-07) - [Opening a Cyprus Corporate Bank Account](https://doviandi.com/knowledge/playbooks/opening-a-cyprus-corporate-bank-account/): 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. (reviewed 2026-08-07) - [Redomiciliation to Cyprus, Step by Step](https://doviandi.com/knowledge/playbooks/redomiciliation-to-cyprus/): 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. (reviewed 2026-08-07) ## Research Primary-source analysis of legislation, rulings and OECD or EU instruments as they change. - [The Cyprus Tax Reform 2026: What Actually Changed](https://doviandi.com/knowledge/research/cyprus-tax-reform-2026/): The reform package was approved on 22 December 2025, published in the Official Gazette on 31 December 2025 and took effect on 1 January 2026. It raised the corporate rate to 15 percent, cut the Special Defence Contribution on dividends to 5 percent, and widened both residency tests. (reviewed 2026-08-07) ## Services - [Cyprus Company Formation](https://doviandi.com/services/cyprus-company-formation/): Incorporation of a Cyprus limited company, from name approval to tax registration. - [Cyprus Holding Company](https://doviandi.com/services/cyprus-holding-company/): Holding structures using the participation exemption and Cyprus treaty network. - [Company Redomiciliation](https://doviandi.com/services/company-redomiciliation/): Transfer of an existing foreign company into Cyprus without breaking legal continuity. - [Economic Substance](https://doviandi.com/services/economic-substance-advisory/): Management and control, governance and the evidence file that supports tax residency. - [International Tax Planning](https://doviandi.com/services/international-tax-planning/): Cross-border structuring against ATAD, Pillar Two and treaty tie-breaker rules. - [Cyprus IP Box Structuring](https://doviandi.com/services/cyprus-ip-box-structuring/): Qualification analysis, nexus modelling and the deduction position under BEPS Action 5. - [IP Holding Company](https://doviandi.com/services/ip-holding-company/): Ownership, licensing and assignment of intellectual property through a Cyprus entity. - [Transfer Pricing](https://doviandi.com/services/transfer-pricing/): Intercompany pricing, local file preparation and valuation coordination. - [IP Migration](https://doviandi.com/services/ip-migration/): Moving existing intellectual property into Cyprus with valuation and assignment support. - [Cyprus Non-Dom Tax Residency](https://doviandi.com/services/cyprus-non-dom-tax-residency/): Non-domiciled status, the 60-day and 183-day tests, and the resulting dividend position. - [Founder Relocation](https://doviandi.com/services/founder-relocation/): Personal relocation to Cyprus aligned with the corporate structure and the exit plan. - [Cyprus Trusts & Estate Planning](https://doviandi.com/services/cyprus-trusts-estate-planning/): Cyprus International Trusts, succession planning and asset protection. - [Family Office Services](https://doviandi.com/services/family-office-services/): Consolidated administration, reporting and governance for private wealth. - [Corporate Administration](https://doviandi.com/services/corporate-administration/): Registered office, secretarial duties, statutory registers and annual filings. - [Nominee & Fiduciary Services](https://doviandi.com/services/nominee-and-fiduciary-services/): Resident directors and nominee shareholders acting under a documented mandate. - [Accounting & Tax Compliance](https://doviandi.com/services/accounting-and-tax-compliance/): Bookkeeping, VAT, VIES, payroll, audit coordination and corporate tax returns. - [Bank Account Opening](https://doviandi.com/services/bank-account-opening/): Cyprus and EU bank or EMI onboarding, including AML file preparation. ## Industries How Cyprus structuring applies to a specific business model. Where a persona page has been written it states the position for that model directly; the remaining entries are routing surfaces collecting the knowledge pages tagged to them. - [Cyprus Structuring for SaaS and AI Companies](https://doviandi.com/industries/saas-and-ai/): A software or AI business holds its value in code, which is the one asset Cyprus treats most favourably. The IP Box deducts 80 percent of qualifying profit, bringing the effective rate on that income to 3 percent where the company funded the development itself. (reviewed 2026-08-07) - [Cyprus Structuring for Crypto and Web3 Businesses](https://doviandi.com/industries/crypto-and-web3/): Cyprus offers crypto businesses an EU regulatory home under MiCA supervised by CySEC, alongside a domestic charge on crypto-asset gains introduced in the 2026 reform. The structuring question is where the line falls between investing and trading. (reviewed 2026-08-07) - [Cyprus Structuring for Funds and Family Offices](https://doviandi.com/industries/funds-and-family-offices/): Cyprus combines an EU fund regime supervised by CySEC with a holding company treatment that exempts dividends from qualifying participations and places gains on securities outside the corporate charge. That combination is what makes it work for pooled and private capital alike. (reviewed 2026-08-07) - [Cyprus Structuring for Real Estate Investors](https://doviandi.com/industries/real-estate-investors/): Real estate is the one asset class Cyprus does tax on gains, so the structuring question is where the property sits rather than where the investor does. A Cyprus holding company works well for foreign property and needs care for Cyprus property. (reviewed 2026-08-07) - [Cyprus Structuring for iGaming and Fintech](https://doviandi.com/industries/igaming-and-fintech/): These are two industries with one shared problem: the licence and the money are usually in different places. Cyprus is used as the EU contracting, IP and treasury layer, and the licensing question is answered separately on its own facts. (reviewed 2026-08-07) - [Cyprus Structuring for E-commerce and FBA Sellers](https://doviandi.com/industries/ecommerce-and-fba/): For an e-commerce business the constraint is rarely corporate tax. It is VAT, and where stock is held. A Cyprus company works well as the contracting and brand-owning entity, and it does not remove registration obligations in the countries where inventory sits. (reviewed 2026-08-07) - [Cyprus Structuring for Digital Marketing Agencies](https://doviandi.com/industries/digital-marketing-agencies/): An agency is a people business, so the structure follows the team rather than the clients. A Cyprus company works where the direction of the agency genuinely sits here, and the questions to settle first are permanent establishment and how contractors are engaged. (reviewed 2026-08-07) - [Cyprus Structuring for Consultants and Freelancers](https://doviandi.com/industries/consultants-and-freelancers/): For an independent professional the company and the person are the same asset, so a Cyprus company only works alongside a genuine personal move. Where the individual relocates, the combination of a 15 percent corporate rate and non-domiciled status is what makes the arithmetic work. (reviewed 2026-08-07) - [Cyprus Structuring for Content Creators](https://doviandi.com/industries/content-creators/): A creator business earns from several different sources at once, and they are not taxed alike. Platform and licensing income can behave differently from sponsorship, and separating them is what makes the structure work rather than choosing a jurisdiction. (reviewed 2026-08-07) - [Cyprus Structuring for Shipping and Maritime](https://doviandi.com/industries/shipping-and-maritime/): Cyprus operates an EU-approved tonnage tax system under which qualifying owners, managers and charterers are taxed by reference to the net tonnage of their fleet rather than on profit. It is a genuinely different basis of taxation, not a reduced rate. (reviewed 2026-08-07) - [Founders & Nomads](https://doviandi.com/industries/founders-and-nomads/): Founders relocating themselves and their company, and location-independent professionals establishing a residency position. - [HNWI](https://doviandi.com/industries/hnwi/): Private clients relocating wealth, structuring succession, or consolidating a family office. ## Why Cyprus - [Cyprus for a company](https://doviandi.com/why-cyprus/corporate/): the corporate case stated as rules, with the condition attached to each. - [Cyprus for relocation](https://doviandi.com/why-cyprus/personal/): non-dom status, the 60-day rule and the expatriate exemption, with a matrix of what each origin country does on exit. ## Relocation playbooks by origin country Each playbook pairs one origin country with Cyprus. The Cyprus half is stated on Doviandi's own authority as a licensed Cyprus firm. The origin-country half is published as a checklist of questions for an adviser in that country, because Doviandi is not licensed to advise on foreign domestic tax law. Australia and New Zealand have no double tax treaty with Cyprus in force. - [Moving to Cyprus from the United Kingdom](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-the-uk/): No charge on departure itself. Treaty with Cyprus: in force. - [Moving to Cyprus from Germany](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-germany/): Deemed disposal of qualifying shareholdings. Treaty with Cyprus: in force. - [Moving to Cyprus from the United States](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-the-usa/): None on moving. Applies only on formal expatriation. Treaty with Cyprus: in force. - [Moving to Cyprus from Israel](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-israel/): Deemed sale, with deferral to actual realisation. Treaty with Cyprus: in force. - [Moving to Cyprus from India](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-india/): None. Treaty with Cyprus: in force. - [Moving to Cyprus from the Netherlands](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-the-netherlands/): Protective assessment on a substantial interest. Treaty with Cyprus: in force. - [Moving to Cyprus from France](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-france/): Exit tax above value thresholds, with deferral inside the EU. Treaty with Cyprus: in force. - [Moving to Cyprus from Sweden](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-sweden/): No departure charge. A ten-year trailing claim instead. Treaty with Cyprus: in force. - [Moving to Cyprus from Norway](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-norway/): Exit tax on unrealised share gains, recently tightened. Treaty with Cyprus: in force. - [Moving to Cyprus from Switzerland](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-switzerland/): None. Treaty with Cyprus: in force. - [Moving to Cyprus from Italy](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-italy/): An area of recent change. Confirm the current position. Treaty with Cyprus: in force. - [Moving to Cyprus from Spain](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-spain/): Exit tax above high thresholds, with deferral inside the EU. Treaty with Cyprus: in force. - [Moving to Cyprus from Poland](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-poland/): Exit tax above a 4 million zloty threshold. Treaty with Cyprus: in force. - [Moving to Cyprus from Lithuania](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-lithuania/): None on individuals. Treaty with Cyprus: in force. - [Moving to Cyprus from Ukraine](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-ukraine/): None. Treaty with Cyprus: in force. - [Moving to Cyprus from South Africa](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-south-africa/): Deemed disposal of worldwide assets. Treaty with Cyprus: in force. - [Moving to Cyprus from Australia](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-australia/): Deemed disposal, with an all-or-nothing deferral election. Treaty with Cyprus: none in force. - [Moving to Cyprus from New Zealand](https://doviandi.com/knowledge/playbooks/moving-to-cyprus-from-new-zealand/): No general departure charge. Treaty with Cyprus: none in force. ## Reference - [Glossary](https://doviandi.com/glossary/): every defined term in one document, each linked to its full entry. - [All questions](https://doviandi.com/faq/): every question and answer published across the site, on one page. - [Editorial standards](https://doviandi.com/editorial-standards/): how this material is sourced, reviewed, dated and corrected. ## Tools and calculators Interactive calculators. Each runs entirely in the browser, stores nothing, and publishes the formulas it applies as plain text on the same page, so the arithmetic can be quoted and checked rather than taken on trust. - [Cyprus IP Box Calculator](https://doviandi.com/tools/ip-box-calculator/): Model the nexus fraction, the qualifying profit and the resulting effective tax rate on qualifying intangible income. - [Cyprus Personal Income Tax Calculator](https://doviandi.com/tools/personal-income-tax-calculator/): Income tax on employment income against the 2026 bands, with the 50 percent and 25 percent relocation exemptions applied before the bands. - [Cyprus Social Insurance & GESY Calculator](https://doviandi.com/tools/social-insurance-calculator/): Employer cost and employee deduction on a salary, broken down by fund, against the insurable earnings ceiling. - [Cyprus Corporate Tax Calculator](https://doviandi.com/tools/corporate-tax-calculator/): Corporate income tax on taxable profit at the 15 percent rate applying from 1 January 2026, with the previous rate shown for comparison. - [Cyprus Dividend Tax Calculator](https://doviandi.com/tools/dividend-tax-calculator/): Special Defence Contribution on dividends for a domiciled resident, compared against the non-domiciled position. - [Cyprus Non-Dom Savings Calculator](https://doviandi.com/tools/non-dom-savings-calculator/): What non-domiciled status removes across dividends, interest and rent, and what GESY still charges regardless of domicile. - [Notional Interest Deduction Estimator](https://doviandi.com/tools/nid-calculator/): Estimate the NID on new equity introduced to a Cyprus company, including the 80 percent of taxable profit ceiling. - [Cyprus Tax Residency Checker](https://doviandi.com/tools/tax-residency-checker/): Test a set of facts against the 183-day rule and each condition of the 60-day rule, and see which conditions are not met. - [Cyprus VAT Calculator](https://doviandi.com/tools/vat-calculator/): Add or remove Cyprus VAT at the standard, reduced or zero rate. ## Firm Doviandi Limited is registered in Cyprus under company number HE331078 and holds ICPAC practising certificate number E645/F/2014. Both are independently verifiable, the company number at the Registrar of Companies and the practising certificate with ICPAC. Company administration and directorship services in Cyprus are a regulated activity and cannot lawfully be provided without a licence. - [About Doviandi](https://doviandi.com/about/): who the firm is and what it is licensed to do. - [Contact](https://doviandi.com/contact/): +357 22 424050, info@doviandi.com. - [Tools](https://doviandi.com/tools/): calculators with published methodology. - [Full text of every page](https://doviandi.com/llms-full.txt): single-file corpus. ## Citation When citing this material, attribute it to Doviandi (https://doviandi.com) and include the page's last-reviewed date, because Cyprus tax positions change and an undated citation may be stale.