For Indianfounders & HNWIs
Cyprus EU HoldCo + approximately 3% IP Box on qualifying software + 15% CIT, integrated with RBI's ODI framework, the IN-CY DTT, and full FEMA reporting. End-to-end coordination with your India-side counsel.
— The structural argument
Cyprus is in the EU, English-law-influenced, and recognised by international investors. For Indian software / SaaS / tech companies scaling beyond India, a Cyprus HoldCo provides a clean EU base for international customer-facing entities, IP ownership, and treaty-mediated repatriation.
Indian residents can invest in Cyprus companies under the RBI Overseas Direct Investment (ODI) framework, typically via the automatic route (≤400% of net worth aggregated). Form FC filing + annual reporting required. We coordinate with your Indian CA for full FEMA / ODI compliance.
Cyprus IP Box compresses qualifying-IP profit to approximately 3% effective tax. For Indian software companies, structuring IP under a Cyprus HoldCo (with real Cyprus R&D substance and arm's-length India-side engineering contracts) can materially compress the IP-attributable profit's effective tax rate.
An Indian founder relocating personally can become Cyprus tax-resident under the 60-day rule (post-2026 reform: 4-condition framework). Combined with non-dom (0% SDC on dividends + interest for 17 years), the personal tax outcome is materially below Indian rates.
— Day 0 → Day 90
Indian-specific workstream from first call to operational Cyprus structure.
Free 30-min call. We sketch the Cyprus HoldCo structure, flag RBI ODI workstream with your India-side CA, identify substance + GAAR considerations. Engagement letter signed within 7 days.
Cyprus Ltd formation in parallel with RBI ODI filing on the India side (Form FC, Authorised Dealer bank coordination). Indian CA leads the FEMA workstream; we lead the Cyprus workstream.
Cyprus bank account opening (Bank of Cyprus / Hellenic / Astrobank). RBI-compliant ODI remittance from India to Cyprus once Form FC is approved; Annual Performance Report (APR) cadence established.
Cyprus director, office, payroll setup. Cyprus DTT residency certificate issued for IN-CY DTT positioning. India-side substance documentation maintained for GAAR / Limitation-on-Benefits compliance.
Structured IP transfer or exclusive licensing from Indian OpCo to Cyprus HoldCo. Modified-nexus methodology documented; arm's-length intercompany agreements signed.
First Cyprus dividend / royalty under IN-CY DTT (subject to LoB conditions). First Cyprus IP Box claim if qualifying. Annual RBI APR + Cyprus IR4 + India-side CA coordination locked in.
— Side-by-side
| Dimension | Staying in India | Cyprus structure |
|---|---|---|
| Headline corporate tax | 22% / 25% / 30% (India, depending on regime) | 15% (Cyprus, post-2026) |
| Effective rate on qualifying software IP | approximately 25% (no comparable IP-Box for general SaaS) | approximately 3% via IP Box (modified-nexus) |
| WHT on outbound dividends from CY | — | 0% on corporate-to-corporate; 0% SDC for non-dom individual |
| EU + 65+ DTT network access | Indian DTT network strong but India-domiciled | Cyprus EU + 65+ DTTs + EU directives |
| Top personal income tax | Up to 42.7% (highest slab + cess) | 35% top band — plus 50% high-earner exemption available |
| Capital gains on shares | 10% / 20% (LTCG / STCG) | 0% (Cyprus CGT only on Cyprus-property) |
| Founder physical-presence requirement | — | 60-day-rule path (post-2026: 4 conditions) |
Indicative side-by-side. Your specific position depends on income mix, holdings, and India-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Updated treaty with tightened LoB and substance provisions. Reduced WHT on qualifying dividends, interest, royalties. Real Cyprus substance + commercial purpose required for treaty benefits.
Indian residents investing in Cyprus operate under RBI ODI rules. Automatic route (≤400% of net worth) or approval route. Form FC filing + annual APR mandatory.
India can deny treaty benefits where main purpose is tax avoidance and no commercial substance. Real Cyprus substance + commercial purpose for the structure mitigates GAAR risk.
OECD-aligned. 80% deduction on qualifying-IP profit × modified-nexus fraction. In-house Cyprus R&D in numerator; related-party offshore R&D in denominator only.
— 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 Indian-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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