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For Indian founders & 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.
A scoping call identifies the proposed Cyprus HoldCo, the India-side RBI ODI workstream and substance or GAAR issues. Timing and responsibilities are then stated in the engagement terms.
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 €1,950 · Relocate & Launch from €4,250 · 60-Day Nomad from €5,850. 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
A seven-day refund policy applies subject to the signed engagement terms. Government and third-party fees are excluded unless those terms state otherwise.
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