What is Austria's Wegzugsbesteuerung?

§27(6) EStG (private capital assets) and §6(6) EStG (business assets) trigger a deemed disposal at fair market value at 27.5% on departure. The Nichtfestsetzung deferral is available for moves to EU/EEA states (Cyprus is in scope) until actual realisation; the deferral was historically open-ended for EU moves but tightened — verify current 7-year cap rules with Austrian counsel.

Is the EU-deferral on Wegzugsbesteuerung automatic?

No. The EU-deferral (Nichtfestsetzung) must be ACTIVELY CLAIMED in the Austrian tax return for the year of departure, with an inventory of relevant assets. Missing the election turns the deferral into immediate cash tax. The election timing + valuation memo are non-negotiable steps.

Can subsequent restructuring trigger the deferred liability?

Yes. Share-for-share transactions, IP migrations, and certain restructurings within the deferral period can crystallise the deferred Austrian tax liability. Coordinate any post-relocation Cyprus restructuring with Austrian counsel — the tax-residence is in Cyprus but the deferred Austrian charge can still bite.

How does the Austria-Cyprus DTT work?

AT-CY DTT (1990). Headline rates: dividends 10%, interest 0%, royalties 0%. Treaty tie-breakers + EU directive supplementation. The 0% interest + 0% royalty position is one of the cleaner positions in Cyprus's network for cross-border financing and IP flows.

What about Austrian SS contributions on relocation?

Combined Austrian SS contributions are ~18% employee + ~21% employer = ~39% — among Europe's heavier. Cessation tied to confirmed non-residency. Coordinate with an Austrian payroll adviser. Pension entitlements continue under Austrian law; payouts are taxed in residence state under the AT-CY DTT (typically residence-state taxation with carve-outs).

Cyprus vs other low-tax destinations for Austrian founders?

Switzerland is the traditional alternative for Austrian HNWs (cantonal flat-tax, lump-sum). Cyprus competes on: 17-year non-dom (vs Swiss bilateral), EU domicile (Switzerland is non-EU), IP Box at ~3%, no inheritance tax (Austria has none, Switzerland varies). Cyprus is structurally simpler for tech / SaaS / IP-heavy founders; Switzerland is heavier-touch but more established for traditional HNW.

For Austrianfounders & HNWIs

Cyprus structures for Austrian founders — Wegzugsbesteuerung-aware

From 23% AT CIT + 55% top PIT + 27.5% KESt + ~39% combined SS to Cyprus 15% / 35% / 0%. EU-deferral on Wegzugsbesteuerung claimed at exit, AT-CY DTT (0% interest + 0% royalties) preserved.

27.5%

AT exit tax

AT-CY interest

AT inheritance tax

Book a free 30-min call See fixed-fee pricing

— The structural argument

Why Austrian founders pick Cyprus

Cyprus 35% top + 50% high-earner exemption vs Austrian ~55%

Austria's top PIT is 55% above €1M (50% above ~€99k). Cyprus 35% top + 50% high-earner exemption + non-dom 0% SDC delivers materially lighter personal taxation.

0% Cyprus CGT on shares vs 27.5% AT KESt

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.

EU Wegzugsbesteuerung deferral preserves the move

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.

AT-CY DTT (1990) — 0% interest + 0% royalties

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

Your Cyprus transition, end-to-end

Austrian-specific workstream from first call to operational Cyprus structure.

Day 0–7: Tri-jurisdictional scope + Austrian counsel
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.
Day 7–25: Cyprus company formation + Austrian exit-tax election prep
Cyprus Ltd formation. Austrian-side §27(6) Nichtfestsetzung election preparation: asset inventory, FMV valuation memo, supporting documentation.
Day 25–55: Cyprus banking + Austrian residency-cut prep
Cyprus bank account opening. Austrian-side Abmeldung + Hauptwohnsitz cessation + economic-centre evidence.
Day 30–70: Yellow Slip + Non-Dom + TIN
Cyprus residence permit (Yellow Slip — EU citizen). Form T.D. 38 non-dom registration. Cyprus TIN.
Day 45–100: Austrian exit-tax election filing
Austrian PIT return for year-of-departure with §27(6) Nichtfestsetzung election filed. Asset inventory documented. Deferral monitoring file opened.
Day 60–120: Operational structure + first compliance
First Cyprus dividend (0% SDC under non-dom). First Cyprus IR4 if year-1 trigger. Austrian-side annual deferral confirmation.

— Side-by-side

Compared to staying in Austria

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)	~3% via IP Box
Combined social contributions	~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

Austria–Cyprus regulatory map

Austria–Cyprus DTT (1990)

Dividends 10%, interest 0%, royalties 0%. EU Parent-Subsidiary Directive supplements.

§27(6) EStG (Wegzugsbesteuerung — private capital)

Triggers on EU/EEA departure. Nichtfestsetzung defers cash payment to actual asset realisation. Must be actively claimed in the year-of-departure tax return.

§6(6) EStG (business-asset exit tax)

Companies / business assets transferred or relocated. Different mechanics from §27(6); often needs separate treatment for founder structures involving operating businesses.

Austrian KSt + Forschungsprämie

23% Austrian CIT + R&D research-bonus regime. The Forschungsprämie is a separate sweetener; doesn't migrate with relocation. Cyprus IP Box (~3%) replaces the IP-side incentive.

— What we handle end-to-end

The full Cyprus transition stack

— 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

Austrian founders ask

Reviewed by

Nexora Editorial Standards Board

ICPAC-coordinated · Cyprus Bar partner-firm

Updated May 2026

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.

“Walked into the call confused, walked out with a 4-step plan, fixed-fee quote, and a Cyprus company set up two weeks later. No surprises on the bill.”

M. Kowalski

SaaS founder · Poland

Published with permission. Initials shown to preserve commercial-privacy preference.

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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

Effective rate on qualifying IP

23% (no comparable IP Box)

~3% via IP Box

Combined social contributions

~39% combined (employee + employer)

GHS 2.65% capped + SI on insurable up to €70,148

Cyprus structures for Austrian founders — Wegzugsbesteuerung-aware

Why Austrian founders pick Cyprus

Cyprus 35% top + 50% high-earner exemption vs Austrian ~55%

0% Cyprus CGT on shares vs 27.5% AT KESt

EU Wegzugsbesteuerung deferral preserves the move

AT-CY DTT (1990) — 0% interest + 0% royalties

Your Cyprus transition, end-to-end

Compared to staying in Austria

Austria–Cyprus regulatory map

Austria–Cyprus DTT (1990)

§27(6) EStG (Wegzugsbesteuerung — private capital)

§6(6) EStG (business-asset exit tax)

Austrian KSt + Forschungsprämie

The full Cyprus transition stack

Austrian founders ask

01How long does the Nichtfestsetzung deferral last?

02Can I keep my Austrian GmbH and just move personally?

03What about Austrian Hauptwohnsitz / Lebensmittelpunkt?

04Can I claim Austrian R&D Forschungsprämie from Cyprus?

05What about ATX-listed share holdings?

06Is the Cyprus 60-day rule available to an Austrian founder?

07Cyprus vs Switzerland for Austrian HNWs?

08Does Cyprus have a German-speaking practitioner network?

Related Cyprus services, tools & guides.

Cyprus structures for Austrian founders — Wegzugsbesteuerung-aware

Why Austrian founders pick Cyprus

Cyprus 35% top + 50% high-earner exemption vs Austrian ~55%

0% Cyprus CGT on shares vs 27.5% AT KESt

EU Wegzugsbesteuerung deferral preserves the move

AT-CY DTT (1990) — 0% interest + 0% royalties

Your Cyprus transition, end-to-end

Compared to staying in Austria

Austria–Cyprus regulatory map

Austria–Cyprus DTT (1990)

§27(6) EStG (Wegzugsbesteuerung — private capital)

§6(6) EStG (business-asset exit tax)

Austrian KSt + Forschungsprämie

The full Cyprus transition stack

Austrian founders ask

01How long does the Nichtfestsetzung deferral last?

02Can I keep my Austrian GmbH and just move personally?

03What about Austrian Hauptwohnsitz / Lebensmittelpunkt?

04Can I claim Austrian R&D Forschungsprämie from Cyprus?

05What about ATX-listed share holdings?

06Is the Cyprus 60-day rule available to an Austrian founder?

07Cyprus vs Switzerland for Austrian HNWs?

08Does Cyprus have a German-speaking practitioner network?

Related Cyprus services, tools & guides.