For Lithuanianfounders & HNWIs
From LT 16% CIT (or 6%/7% small-co at sub-€300k) + 32% top PIT + 19.5% SS to Cyprus 15% + IP Box approximately 3% + 35% top + 50% high-earner exemption + non-dom 0% SDC. LT-CY DTT 0/0/5 — clean EU corridor.
— The structural argument
Lithuanian 6%/7% small-co rate caps out at €300k revenue. As you scale past, standard 16% LT CIT applies. Cyprus 15% + IP Box (approximately 3% on qualifying IP) becomes structurally lighter, especially for IP-heavy and software businesses.
Lithuanian top PIT 32% + 19.5% SS = approximately 52% combined wedge on active income. Cyprus 35% top + 50% high-earner exemption + non-dom 0% SDC delivers materially lighter founder personal-tax position.
Lithuanian-Cyprus DTT (2014): 0% dividends, 0% interest, 5% royalties. EU Parent-Subsidiary Directive supplements: 0% on qualifying corporate-to-corporate dividends. Among the cleaner EU treaty corridors.
Lithuanian inheritance: 5% (≤€150k) / 10% (above), with spouse + lineal descendants exempt. Cyprus inheritance: 0% (abolished). For founders building generational wealth, the inheritance differential is material.
— Day 0 → Day 90
Lithuanian-specific workstream from first call to operational Cyprus structure.
Free 30-min call. Sketch Cyprus structure; flag UAB retention vs migration; identify substance separation; Lithuanian CFC + PoEM analysis. Lithuanian counsel engaged.
Cyprus Ltd formation. Lithuanian-side: maintain UAB substance (board, banking, management) if retaining for LT-customer operations; or plan dissolution / migration.
Cyprus bank account opening. Personal Lithuanian SS / NHIF deregistration. Address update with VMI.
Cyprus residence permit (Yellow Slip — EU citizen). Form T.D. 38 non-dom registration. Cyprus TIN.
If retaining: UAB substance documented + intercompany pricing locked in. If dissolving: liquidator + VMI cessation.
First Cyprus dividend (0% SDC under non-dom). Cyprus IR4 cycle. Annual compliance plan locked in.
— Side-by-side
| Dimension | Staying in Lithuania | Cyprus structure |
|---|---|---|
| Headline corporate tax | 16% standard / 6% (rising to 7% in 2026) small-co (≤€300k) | 15% / approximately 3% via IP Box on qualifying |
| Top personal income tax | 32% above approximately €114k | 35% top + 50% high-earner exemption |
| Capital gains on shares | 15-20%; participation exemption for >10% / >2yr EEA holdings | 0% (only Cyprus-property) |
| Dividend WHT outbound (treaty) | 0% (LT-CY DTT) | 0% |
| Inheritance tax (close family) | Spouse + lineal exempt; otherwise 5% / 10% | 0% |
| Combined social contributions | approximately 21% combined (19.5% emp + 1.77% employer) | GHS 2.65% capped + SI on insurable up to €70,148 |
| Effective rate on qualifying IP | 16% (no comparable IP Box) | approximately 3% via IP Box |
Indicative side-by-side. Your specific position depends on income mix, holdings, and Lithuania-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Dividends 0%, interest 0% (residence-state), royalties 5% max. EU directive supplementation.
6% (rising to 7% from 2026) for qualifying small companies (<10 employees, <€300k revenue). New small companies: 0% in first year. Caps out at scale.
Gains on EEA/treaty-country company shares held >2 years and >10% are exempt. Layered structures with LT participation exemption + Cyprus participation exemption can be efficient cross-border.
If UAB management runs from Cyprus, Lithuanian CFC + PoEM tests can re-attribute UAB profits to Cyprus-tax-resident control. Substance separation matters operationally, not just formally.
— 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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