For Estonianfounders & HNWIs
Estonia is the accumulation jurisdiction (22% on distribution only). Cyprus is the realisation jurisdiction (0% non-dom dividends, 0% CGT on shares). EE-CY DTT 0/0/0 WHT — the cleanest EU treaty corridor.
— The structural argument
Estonian distribution-only CIT is paid at 22% (raised from 20% in 2025) when profits are distributed. Cyprus non-dom: 0% SDC on dividends + interest for 17 years on the founder-receipt side. Slow-distribution + Cyprus residency delivers materially better economics on cash-out.
Estonia-Cyprus DTT: 0% dividends, 0% interest, 0% royalties between qualifying entities. Among the cleanest treaty positions in Europe. Combined with EU Parent-Subsidiary Directive on corporate-to-corporate flows, the cross-border plumbing is uniquely efficient.
Maintain the Estonian OÜ (Estonian distribution-only CIT) for the operating business; relocate personally to Cyprus for residency + non-dom benefits on dividend extraction. The structural pattern leverages both regimes' strengths.
Estonia: 0% inheritance (already neutral). Cyprus: 0% inheritance (also abolished). EU stability + Mediterranean lifestyle distinguishes the relocation case from a pure-tax-arbitrage move.
— Day 0 → Day 90
Estonian-specific workstream from first call to operational Cyprus structure.
Free 30-min call. Sketch Cyprus structure; flag OÜ retention vs migration; identify EE-side substance maintenance. Estonian counsel engaged for the Estonian-side workstream.
Cyprus Ltd formation. Estonian-side: ensure the OÜ retains Estonian board, decisions, and management substance to maintain Estonian-tax-residence.
Cyprus bank account opening. Personal Estonian SS / health-fund deregistration; e-Residency typically maintained (no conflict with Cyprus residency).
Cyprus residence permit (Yellow Slip — EU citizen). Form T.D. 38 non-dom registration. Cyprus TIN.
Estonian distribution strategy: slow-distribution to maximise Cyprus non-dom advantage. EE-CY DTT positioning documented.
First Estonian distribution under EE-CY DTT 0% WHT + Cyprus 0% SDC under non-dom = effectively 22% Estonian CIT on distribution + 0% personal-side. Annual cycle locked in.
— Side-by-side
| Dimension | Staying in Estonia | Cyprus structure |
|---|---|---|
| Headline corporate tax | 22% on distribution only (raised from 20% Jan 2025) | 15% on accruing profit |
| Top personal income tax | 22% flat (raised from 20% in 2025) | 35% top + 50% high-earner exemption |
| Capital gains on shares | 22% flat | 0% (only Cyprus-property) |
| Dividend WHT (EE → CY treaty) | — | 0% (EE-CY DTT) |
| Inheritance tax | 0% | 0% |
| Effective rate on qualifying IP | 22% on distribution (no IP Box) | approximately 3% via IP Box |
| Founder distribution-cycle planning | All-at-once = 22% / Slow = same effective rate but timed | Slow distribution to non-dom + 0% SDC = significantly better timing economics |
Indicative side-by-side. Your specific position depends on income mix, holdings, and Estonia-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Headline rates 0% / 0% / 0% — among the cleanest EU corridors. Treaty tie-breakers resolve dual-residency questions during transition.
22% on distribution only (raised from 20% in 2025). Undistributed profits untaxed. Effective rate on distribution = 22/78 (the gross-up structure).
ATAD-aligned. Triggers on corporate residency change. For individuals: no broad personal exit tax — actual disposal only.
Both EU. 0% WHT on qualifying corporate-to-corporate dividends (≥10% / ≥24 months) between Estonian and Cyprus subs — supplements the already-zero EE-CY DTT rates.
— 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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