For Belgianfounders & HNWIs
From 25% BE CIT + 53.5% top PIT + new 10/33% CGT (Jan 2026) + regional inheritance up to 80% to Cyprus 15% / 35% / 0%. Pre-1-Jan-2026 cost-basis lock-in is the critical timing window.
— The structural argument
Belgian regional inheritance can hit 80% in Brussels for unrelated heirs. Cyprus inheritance tax: 0% (abolished). For founders building generational wealth, the inheritance differential is the dominant structural argument — even before considering the new 2026 CGT regime.
The new Belgian CGT regime (10% / 33%) applies only to post-31-Dec-2025 gains. Cyprus relocation before 1 Jan 2026 locks in pre-regime cost basis on Belgian-sited assets. Cyprus residency thereafter shifts disposals to 0% Cyprus CGT.
Belgian expat regime is inbound (up to 30% of salary tax-free, cap €90k, 5+3 year duration). Cyprus non-dom is the outbound: 0% SDC on dividends + interest, 17 years, no minimum-tax. For founder-equity events + dividend extraction, Cyprus is materially deeper.
Both EU. Qualifying corporate-to-corporate dividends flow at 0% WHT under the EU directive (≥10% / ≥24 months). BE-CY DTT (1996) supplements with reduced WHT on individual flows.
— Day 0 → Day 90
Belgian-specific workstream from first call to operational Cyprus structure.
Free 30-min call. We sketch the Cyprus structure, flag the 1-Jan-2026 CGT timing, identify regional inheritance + ATAD III considerations. Belgian tax counsel engaged.
Cyprus Ltd formation. Belgian-side: 31-Dec-2025 valuation memo for cost-basis lock-in (if relocating in 2026).
Cyprus bank account opening. Belgian-side residency-cut documentation: commune deregistration, tax-residency-cut filing, Cyprus economic-centre evidence.
Cyprus residence permit (Yellow Slip — EU citizen). Form T.D. 38 non-dom registration. Cyprus TIN.
Belgian-sited property restructuring (where applicable) for regional inheritance mitigation. Cyprus HoldCo positioning if Belgian SCI / SC in scope.
First Cyprus dividend (0% SDC under non-dom). Annual cycle: Cyprus IR4 + Belgian non-resident return for residual.
— Side-by-side
| Dimension | Staying in Belgium | Cyprus structure |
|---|---|---|
| Headline corporate tax | 25% standard / 20% SME first €100k | 15% |
| Top personal income tax | approximately 53.5% (50% federal + approximately 7% municipal) | 35% + 50% high-earner exemption |
| Capital gains on shares (from 2026) | 10% (>€10k/yr) / 33% (substantial holdings) | 0% (only Cyprus-property) |
| Inheritance tax | Regional: 3-30% direct line / up to 80% unrelated (Brussels) | 0% |
| Effective rate on qualifying IP | 25% (no IP Box equivalent) | approximately 3% via IP Box |
| Combined social contributions | approximately 38% combined (employee + employer) | GHS 2.65% capped + SI on insurable up to €70,148 |
| Wealth / solidarity tax | Variable; some regional+communal levies | 0% — no wealth tax |
Indicative side-by-side. Your specific position depends on income mix, holdings, and Belgium-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Dividends 10/15%, interest 10%, royalties 0%. Treaty tie-breakers + EU directive supplementation.
10% on financial-asset gains > €10k/yr; 33% on substantial-holding disposals to related parties. Effective 1 Jan 2026. Pre-2026 cost basis must be documented at 31 Dec 2025 to be protected.
Up to 80% in Brussels for unrelated heirs. Belgian-sited property remains in regional scope regardless of Cyprus residency. Pre-relocation restructuring (Cyprus HoldCo) is the standard mitigation.
Brussels-led anti-shell-company directive. Cyprus structures with real Cyprus substance pass; pure-conduit structures fail. Substance discipline + decision-making documentation are essential.
— 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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