For Germanfounders & HNWIs
From a approximately 30% combined corporate burden + 47.5% top personal rate to a 15% Cyprus CIT, approximately 3% IP Box effective, and 0% SDC under non-dom — without losing the EU Parent-Subsidiary path. Structured exit, structured arrival.
— The structural argument
German combined effective rate routinely lands at approximately 30% (KSt + Soli + Gewerbesteuer). Cyprus is 15% headline, with the IP Box compressing qualifying-IP profit to approximately 3% effective. EU membership, EU Parent-Subsidiary Directive, and 65+ DTTs preserved.
A Cyprus tax-resident German non-dom faces 0% Special Defence Contribution on dividends and interest for 17 years. Combine with the 50% high-earner PIT exemption (€55k+ salary) and a Cyprus shareholder structure — the personal tax burden compresses dramatically.
§6 AStG triggers an exit tax on substantial shareholdings. EU destinations qualify for the 7-instalment plan rather than immediate payment. We coordinate with your German tax adviser to time the valuation, structure the instalments, and document the residency switch defensibly.
Cyprus corporate bank accounts (Bank of Cyprus, Hellenic, Astrobank) and EMI options (Wise Business, Revolut Business) sequenced into the formation — typical end-to-end onboarding 30–60 days from incorporation. Substance via local director + office service from day one.
— Day 0 → Day 90
German-specific workstream from first call to operational Cyprus structure.
Free 30-min call. We confirm fit, sketch the Cyprus structure, flag the German-side workstream (Wegzugsteuer trigger date, valuation, parallel filings). Engagement letter signed within 5 days.
HE1/HE2/HE3 + M&AA with German-translated documents where required. TIN + UBO Register filing. Standard track 10–15 days; expedited track 5–10 days available.
Cyprus bank introduction (Bank of Cyprus / Hellenic / Astrobank) + EMI fallback (Wise Business / Revolut Business). KYC pack pre-prepared; we manage the bank-side correspondence.
Yellow Slip (Cyprus residence permit), Form T.D. 38 (non-dom registration), 60-day-rule documentation. We file every form and chase Tax Department where needed.
Abmeldung filing in coordination with your German tax adviser. Wegzugsteuer-related gain valuation, instalment plan election where applicable. Final German PIT return.
First Cyprus dividend distribution under non-dom (0% SDC). First Cyprus payroll if salary track. IP Box claim filed if qualifying. Year-1 compliance plan locked in.
— Side-by-side
| Dimension | Staying in Germany | Cyprus structure |
|---|---|---|
| Headline corporate tax | Körperschaftsteuer 15% + Soli + Gewerbesteuer approximately 14–17% → approximately 30% combined | 15% CIT (post-2026 reform) |
| Effective rate on IP profit | approximately 30% (no comparable patent box for software) | approximately 3% via IP Box (modified-nexus) |
| Withholding on outbound dividends | Abgeltungsteuer 25% + Soli (approximately 26.4%) on individual receipt | 0% on corporate-to-corporate; 0% SDC for non-dom individual |
| Top personal income tax | 47.5% (incl. Soli + church tax) | 35% top band (€72k+) — plus 50% high-earner exemption available |
| Capital gains on shares | 26.4% Abgeltungsteuer | 0% (Cyprus CGT only on Cyprus-property) |
| Inheritance tax exposure | Up to 50% | 0% — abolished |
| Annual compliance burden | Multiple authorities + €5k–€15k/year typical | From €1,600/year ongoing — see /pricing |
Indicative side-by-side. Your specific position depends on income mix, holdings, and Germany-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Treaty in force; reduced WHT on dividends and interest. Treaty tie-breakers resolve dual-residency questions during transition.
Cyprus is in scope. Qualifying corporate-to-corporate dividend flows between Cyprus and German subsidiaries flow free of WHT (≥10% holding for ≥24 months).
German exit tax on substantial shareholdings (≥1%, 7-of-12-year German residency). EU/EEA destinations qualify for the 7-year instalment plan; not avoidable but manageable.
Germany's CFC regime can attribute Cyprus subsidiary income back to a German shareholder if the Cyprus entity is treated as low-taxed and passive. Real Cyprus substance + active-income mix mitigates exposure.
— 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
Read the full German-founder Cyprus relocation guide — every form, every fee, every workstream documented.
Read the full guide— 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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