For Italianfounders & HNWIs
From Italy's approximately 28% combined CIT + 46% top PIT + 26% CGT to Cyprus 15% / 35% / 0%. Coordinated AIRE deregistration, IT-CY DTT positioning, Cyprus 17-year non-dom — the structural case beats Italy's HNW flat tax for most founders.
— The structural argument
Cyprus non-dom regime: 0% Special Defence Contribution on dividend and interest income for 17 years. Italy's HNW flat-tax (€200k/yr, rising to €300k from 2026) competes — but Cyprus has no minimum-tax floor and a longer window for most founders.
Cyprus capital gains tax applies only to Cyprus-situs immovable property — share sales (listed, unlisted, founder equity) face 0% Cyprus CGT. Cyprus inheritance tax was abolished. Italy: 26% CGT on shares + inheritance tax up to 8% (lineage-dependent).
Italy and Cyprus are both EU. Qualifying corporate-to-corporate dividend flows between Italian OpCo and Cyprus HoldCo benefit from the EU Parent-Subsidiary Directive (0% WHT, ≥10% holding for ≥24 months). The IT-CY DTT supplements with reduced WHT on individual flows.
Italy's residency-determination framework looks at AIRE registration + day count + economic ties. We coordinate AIRE deregistration with the Cyprus arrival workstream to ensure the residency switch is defensible from the year of departure forward.
— Day 0 → Day 90
Italian-specific workstream from first call to operational Cyprus structure.
Free 30-min call. We sketch the Cyprus structure, flag the Italian §166 / HNW-monitoring / AIRE workstream, identify CFC + transfer-pricing considerations on any Italian-OpCo restructuring. Italian tax adviser engaged from day one.
Cyprus Ltd formation in parallel with Italian-side preparation: AIRE-deregistration documentation, Italian residency-cut evidence (Cyprus property, day-count log).
Cyprus bank account opening (Bank of Cyprus / Hellenic / Astrobank). Italian tax-clearance for any cross-border flows. AIRE filing.
Cyprus residence permit (Yellow Slip for EU citizens). Form T.D. 38 non-dom registration. Cyprus TIN.
If IP-Box is in play: structured IP transfer or licensing to Cyprus IPCo with Italian-side §178 / §165-bis analysis. Modified-nexus methodology documented.
First Cyprus dividend under non-dom (0% SDC). First post-relocation Italian residency-cut return (mod. UNICO PF or ISR equivalent). Annual compliance plan locked in.
— Side-by-side
| Dimension | Staying in Italy | Cyprus structure |
|---|---|---|
| Headline corporate tax | 24% IRES + 3.9% IRAP ≈ 28% combined | 15% (Cyprus, post-2026) |
| Top personal income tax | approximately 46% (43% IRPEF + regional + municipal) | 35% top + 50% high-earner exemption available |
| Capital gains on shares | 26% flat (substitute tax) | 0% (only on Cyprus-property) |
| Inheritance tax | 4–8% depending on relation (low €1m exemption per heir for spouse/children) | 0% — abolished |
| Effective rate on qualifying software IP | approximately 28% (no comparable IP Box) | approximately 3% via IP Box (modified-nexus) |
| Top HNW regime | Italian flat-tax €200k–€300k/yr foreign-source | Non-dom: 0% SDC dividends + interest for 17 years (no min-tax) |
| Social contributions on active income | INPS 24–26%+ self-employed | GHS 2.65% (capped); SI on insurable up to €70,148 |
Indicative side-by-side. Your specific position depends on income mix, holdings, and Italy-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Treaty in force; reduced WHT on cross-border dividends/interest/royalties. Treaty tie-breakers resolve dual-residency questions during transition. MLI may modify; verify with adviser.
Cyprus is in scope. Qualifying corporate-to-corporate dividends between Italian and Cyprus subsidiaries flow at 0% WHT (≥10% holding for ≥24 months).
Applies to business assets / companies relocating residence. Triggers tax on unrealised gains. EU/EEA destinations qualify for installment / deferral mechanisms; Cyprus is in scope.
Italian residency proof; failure to register with AIRE on departure exposes founders to continued Italian residency assessments. Cyprus residency switch must be paired with AIRE filing.
— 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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