For Romanianfounders & HNWIs
Romania's micro-company threshold dropped to €100k in 2026 — many founders need a successor jurisdiction at scale. Cyprus 15% CIT + IP Box (approximately 3%) + 0% non-dom dividends + 17-year window.
— The structural argument
For Romanian founders scaling past €100k revenue (the new micro-co threshold), Cyprus offers a coherent successor jurisdiction: 15% standard CIT, approximately 3% effective on qualifying IP (IP Box modified-nexus), EU domicile, 65+ DTTs.
Cyprus non-dom: 0% SDC on dividends + interest for 17 years. Romanian dividend WHT 10% (treaty rate to Cyprus). For founder-equity events + dividend extraction, the Cyprus offer is materially lighter.
Romania's micro-company narrowing, IT/HoReCa exemption changes, 3% rate adjustments — recent reform pace creates uncertainty. Cyprus's stable EU framework with 65+ DTTs provides multi-year structuring predictability.
Treaty rates: dividends 10%, interest 10%, royalties 5%. EU Parent-Subsidiary Directive supplements: 0% on qualifying corporate-to-corporate dividends (≥10% / ≥24 months).
— Day 0 → Day 90
Romanian-specific workstream from first call to operational Cyprus structure.
Free 30-min call. Sketch Cyprus structure; flag Romanian SRL dissolution-vs-maintenance decision; identify operational substance separation. Romanian counsel engaged.
Cyprus Ltd formation. Romanian SRL: dissolve / migrate / maintain decision based on customer base and operational substance.
Cyprus bank account opening. Romanian-side deregistration of CASS/CAS contributions if relocating personally. Address update with ANAF.
Cyprus residence permit (Yellow Slip — EU citizen). Form T.D. 38 non-dom registration. Cyprus TIN.
If dissolving: liquidator + Form ANAF cessation. If maintaining: substance separation between Cyprus and Romanian operations.
First Cyprus dividend (0% SDC under non-dom). First Cyprus IR4 cycle. Annual compliance plan locked in.
— Side-by-side
| Dimension | Staying in Romania | Cyprus structure |
|---|---|---|
| Headline corporate tax | 16% standard / 1-3% micro (≤€100k) | 15% / approximately 3% via IP Box on qualifying |
| Top personal income tax | 10% flat (low headline, high SS wedge) | 35% top + 50% high-earner exemption |
| Capital gains on shares | 10% (treated as investment income) | 0% (only Cyprus-property) |
| Dividend WHT outbound (treaty) | 5% (EU PSD) / 10% otherwise | 0% |
| Inheritance tax | 0% (no inheritance/gift tax) | 0% |
| Combined social contributions | approximately 25% employee + employer var | GHS 2.65% capped + SI on insurable up to €70,148 |
| Effective rate on qualifying IP | 16% (no IP Box) | approximately 3% via IP Box |
Indicative side-by-side. Your specific position depends on income mix, holdings, and Romania-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Dividends 10%, interest 10%, royalties 5%. EU directive supplementation.
Revenue threshold dropped €500k → €250k → €100k. IT/HoReCa exemptions narrowed. Founders past €100k need a successor jurisdiction.
16% on unrealised gains for corporate residency change. For individuals: standard CGT only on actual disposal — no broad personal exit tax.
Both EU. 0% WHT on qualifying corporate-to-corporate dividends (≥10% / ≥24 months) between Romanian and Cyprus subs.
— 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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