For Israelifounders & HNWIs
A Cyprus HoldCo over your Israeli OpCo: EU-domiciled, English-law-friendly, approximately 3% IP Box on qualifying software, IL-CY DTT (0–5% WHT). The structural choice for Israeli tech going to a US listing.
— The structural argument
Cyprus is an EU-domiciled, English-law-influenced jurisdiction that US institutional investors recognise. A Cyprus HoldCo over an Israeli OpCo is one of the cleanest pre-IPO structures for Israeli tech going to NASDAQ / NYSE — avoids Israeli-HoldCo-on-S-1 friction.
Cyprus IP Box (under modified-nexus): 80% deduction on qualifying-IP profit → approximately 3% effective tax for Cyprus-owned software, patents, and copyrighted code. Materially below Israel's headline 23% (or Preferred Technology Enterprise reduced rates).
0% WHT on inter-bank interest, 5% on other interest, 0% royalties (between qualifying companies). The Israel-Cyprus DTT gives the cleanest treaty position for cross-border IP, financing, and dividend flows in the structure.
An Israeli founder relocating personally can qualify for Cyprus tax residency under the 60-day rule (post-2026 reform: 4 conditions). Combined with non-dom (0% SDC on dividends + interest for 17 years) and the 50% high-earner PIT exemption, the personal tax outcome is materially lower than Israeli rates.
— Day 0 → Day 90
Israeli-specific workstream from first call to operational Cyprus structure.
Free 30-min call. We sketch the Cyprus HoldCo + Israeli OpCo structure, flag the Israeli exit-tax workstream, identify US-side requirements if a listing is on the horizon. Engagement letter signed within 7 days.
Cyprus Ltd formation in parallel with Israeli tax counsel preparing the exit-tax position (if founder-side) and the IL-side restructuring (if corporate-side IP transfer). Coordinated timeline — both must align.
Cyprus bank account opening (Bank of Cyprus / Hellenic / Astrobank). DTT residency certificates issued by both jurisdictions where required for the IL-CY treaty positioning.
If the founder is relocating personally: Yellow Slip residence permit, Form T.D. 38 non-dom registration, Cyprus TIN. The 60-day-rule day-count starts from first Cyprus presence.
If the IP Box is in scope: structured transfer or exclusive licensing of qualifying IP from Israeli OpCo to Cyprus HoldCo. Modified-nexus methodology documented; intercompany agreements signed.
First Cyprus dividend / interest flow under the IL-CY DTT. First Cyprus IP Box claim in the IR4 corporate tax return. Annual compliance plan locked in. If US listing is forthcoming: pre-IPO structure documentation finalised with US counsel.
— Side-by-side
| Dimension | Staying in Israel | Cyprus structure |
|---|---|---|
| Headline corporate tax | 23% (Israel) | 15% (Cyprus, post-2026) |
| Effective rate on qualifying software IP | Approved Enterprise / Preferred Tech Enterprise rates 6–12% if qualifying | approximately 3% via IP Box (modified-nexus) |
| WHT on inter-company interest (IL ↔ CY) | — | 0% (IL-CY DTT, inter-bank); 5% other interest |
| WHT on royalties (IL ↔ CY) | — | 0% (IL-CY DTT, qualifying flows) |
| EU-domicile holding suitability | Israeli HoldCo on US S-1 has structural friction | EU domicile, English-law-friendly, US-investor-comfortable |
| Founder personal tax (post-relocation) | Up to 50% (Israel marginal) | 0% SDC under non-dom + 50% high-earner exemption available |
| Capital gains on shares | 25–28% (Israel) | 0% (Cyprus CGT only on Cyprus-property) |
Indicative side-by-side. Your specific position depends on income mix, holdings, and Israel-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Modern treaty. 0% inter-bank interest, 5% other interest, 0% royalties (qualifying flows), reduced dividend WHT. One of the cleanest treaty positions in Cyprus's network for Israeli-tech structures.
OECD-aligned. 80% deduction on qualifying-IP profit × modified-nexus fraction. Cyprus-developed or Cyprus-owned software qualifies; IP licensed-in from related parties suffers the nexus-denominator penalty.
Triggered on Israeli-resident-individual departure for substantial shareholdings. Coordination with Israeli tax counsel BEFORE the move is essential. Installment-payment options available under specific conditions.
Foreign-subsidiary dividends received by a Cyprus parent are 0% Cyprus CIT + 0% SDC where the 3-test diagnostic passes (subject-to-tax + active-income + anti-abuse). Israeli-OpCo dividends to Cyprus-HoldCo typically pass the diagnostic.
— 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 Israeli-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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