For Austrianfounders & HNWIs
From 23% AT CIT + 55% top PIT + 27.5% KESt + approximately 39% combined SS to Cyprus 15% / 35% / 0%. EU-deferral on Wegzugsbesteuerung claimed at exit, AT-CY DTT (0% interest + 0% royalties) preserved.
— The structural argument
Austria's top PIT is 55% above €1M (50% above approximately €99k). Cyprus 35% top + 50% high-earner exemption + non-dom 0% SDC delivers materially lighter personal taxation.
Austrian Kapitalertragsteuer is 27.5% final WHT on dividends + capital gains from securities. Cyprus 0% CGT on shares (only Cyprus-property in scope) is a clean structural win.
Cyprus, as an EU member, qualifies for Austria's Nichtfestsetzung mechanism — deferring exit-tax payment to actual asset realisation rather than immediate cash on departure. The election timing + valuation memo are coordinated upfront.
Modern treaty positioning. Dividends 10%, interest 0%, royalties 0%. Combined with EU Parent-Subsidiary Directive on qualifying corporate-to-corporate dividend flows, the cross-border plumbing is exceptionally clean.
— Day 0 → Day 90
Austrian-specific workstream from first call to operational Cyprus structure.
Free 30-min call. We sketch the Cyprus structure, flag the §27(6) EStG / Nichtfestsetzung workstream, identify any Austrian KSt / corporate-side restructuring needs. Austrian tax counsel engaged.
Cyprus Ltd formation. Austrian-side §27(6) Nichtfestsetzung election preparation: asset inventory, FMV valuation memo, supporting documentation.
Cyprus bank account opening. Austrian-side Abmeldung + Hauptwohnsitz cessation + economic-centre evidence.
Cyprus residence permit (Yellow Slip — EU citizen). Form T.D. 38 non-dom registration. Cyprus TIN.
Austrian PIT return for year-of-departure with §27(6) Nichtfestsetzung election filed. Asset inventory documented. Deferral monitoring file opened.
First Cyprus dividend (0% SDC under non-dom). First Cyprus IR4 if year-1 trigger. Austrian-side annual deferral confirmation.
— Side-by-side
| Dimension | Staying in Austria | Cyprus structure |
|---|---|---|
| Headline corporate tax | 23% (reduced 2024 from 24%) | 15% |
| Top personal income tax | 55% above €1M / 50% above €99k | 35% + 50% high-earner exemption |
| Capital gains on shares (KESt) | 27.5% final WHT | 0% (only Cyprus-property) |
| Exit tax (Wegzugsbesteuerung) | 27.5% on unrealised gains; EU-deferral via Nichtfestsetzung | — |
| Inheritance tax | 0% (abolished 2008); RE transfer tax remains | 0% |
| Effective rate on qualifying IP | 23% (no comparable IP Box) | approximately 3% via IP Box |
| Combined social contributions | approximately 39% combined (employee + employer) | GHS 2.65% capped + SI on insurable up to €70,148 |
Indicative side-by-side. Your specific position depends on income mix, holdings, and Austria-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Dividends 10%, interest 0%, royalties 0%. EU Parent-Subsidiary Directive supplements.
Triggers on EU/EEA departure. Nichtfestsetzung defers cash payment to actual asset realisation. Must be actively claimed in the year-of-departure tax return.
Companies / business assets transferred or relocated. Different mechanics from §27(6); often needs separate treatment for founder structures involving operating businesses.
23% Austrian CIT + R&D research-bonus regime. The Forschungsprämie is a separate sweetener; doesn't migrate with relocation. Cyprus IP Box (approximately 3%) replaces the IP-side incentive.
— What we handle end-to-end
— Fixed-fee, transparent
Tax Resident from €1,899 · Relocate & Launch from €4,899 · 60-Day Nomad from €5,899. All + VAT. No "contact us for a quote".
See full relocation pricing— Common questions
— EVERYTHING INCLUDED
If your Cyprus Ltd, residency permit, or Non-Dom declarations are not delivered for any reason within our control, we refund 100% of the professional fee. Government disbursements pass through at cost.
Engagements coordinated with ICPAC-registered Cyprus tax advisers and Cyprus Bar Association member-firm lawyers. MOKAS-aligned under Cyprus AML Law 188(I)/2007. See our editorial standards and disclaimer.
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