What changed for Romanian micro-enterprises?

Romania has progressively narrowed the micro-company regime: revenue threshold dropped from €500k → €250k → €100k (effective 2026), IT/HoReCa exemptions narrowed, 3% rate for some activities. Many founders who structured around 1-3% revenue tax have been stranded. Cyprus 15% CIT + IP Box (~3% effective) + 0% non-dom dividends becomes the natural successor jurisdiction at scale.

Does Romania have an exit tax on individuals?

Romania applies a 16% ATAD-based corporate exit tax (effective 2018) on residency change of companies. For individuals, Romania does not have a specific personal exit tax beyond standard CGT on actual disposal. Personal-side relocation is structurally simpler than e.g. Italy or Spain.

Does Romania have inheritance tax?

No — Romania has no inheritance or gift tax (subject to a small notarial fee if estate settled within 2 years). Cyprus also 0%. Inheritance is neutral on the comparison.

How does the Romania-Cyprus DTT work?

RO-CY DTT signed 1981 (revised). Headline rates: dividends 10%, interest 10%, royalties 5%. EU directive supplementation on qualifying corporate-to-corporate flows. Treaty tie-breakers + standard EU mechanics.

What about Romanian SS contributions?

Combined Romanian SS: 25% employee (10% pension + 10% health + 5% misc) + employer contributions. Cessation tied to confirmed non-residency. Coordinate with Romanian payroll adviser.

For Romanianfounders & HNWIs

Cyprus structures for Romanian founders — post-micro-co reform

Romania's micro-company threshold dropped to €100k in 2026 — many founders need a successor jurisdiction at scale. Cyprus 15% CIT + IP Box (~3%) + 0% non-dom dividends + 17-year window.

€100k

RO micro threshold

15%

CY CIT

RO + CY inheritance

Book a free 30-min call See fixed-fee pricing

— The structural argument

Why Romanian founders pick Cyprus

Cyprus 15% CIT + IP Box ~3% as the post-micro-co successor

For Romanian founders scaling past €100k revenue (the new micro-co threshold), Cyprus offers a coherent successor jurisdiction: 15% standard CIT, ~3% effective on qualifying IP (IP Box modified-nexus), EU domicile, 65+ DTTs.

Cyprus 0% SDC vs Romanian 10%+ dividend WHT

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.

EU stability vs Romanian regulatory churn

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.

RO-CY DTT (1981) + EU directive plumbing

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

Your Cyprus transition, end-to-end

Romanian-specific workstream from first call to operational Cyprus structure.

Day 0–7: Tri-jurisdictional scope
Free 30-min call. Sketch Cyprus structure; flag Romanian SRL dissolution-vs-maintenance decision; identify operational substance separation. Romanian counsel engaged.
Day 7–25: Cyprus company formation + Romanian decision
Cyprus Ltd formation. Romanian SRL: dissolve / migrate / maintain decision based on customer base and operational substance.
Day 25–55: Cyprus banking + Romanian deregistration
Cyprus bank account opening. Romanian-side deregistration of CASS/CAS contributions if relocating personally. Address update with ANAF.
Day 30–70: Yellow Slip + Non-Dom + TIN
Cyprus residence permit (Yellow Slip — EU citizen). Form T.D. 38 non-dom registration. Cyprus TIN.
Day 45–100: Romanian SRL final compliance
If dissolving: liquidator + Form ANAF cessation. If maintaining: substance separation between Cyprus and Romanian operations.
Day 60–120: Operational structure + first compliance
First Cyprus dividend (0% SDC under non-dom). First Cyprus IR4 cycle. Annual compliance plan locked in.

— Side-by-side

Compared to staying in Romania

Dimension	Staying in Romania	Cyprus structure
Headline corporate tax	16% standard / 1-3% micro (≤€100k)	15% / ~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	~25% employee + employer var	GHS 2.65% capped + SI on insurable up to €70,148
Effective rate on qualifying IP	16% (no IP Box)	~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

Romania–Cyprus regulatory map

Romania–Cyprus DTT (1981, revised)

Dividends 10%, interest 10%, royalties 5%. EU directive supplementation.

Romanian micro-enterprise regime (narrowed 2024-2026)

Revenue threshold dropped €500k → €250k → €100k. IT/HoReCa exemptions narrowed. Founders past €100k need a successor jurisdiction.

Romanian ATAD-based corporate exit tax

16% on unrealised gains for corporate residency change. For individuals: standard CGT only on actual disposal — no broad personal exit tax.

EU Parent-Subsidiary Directive

Both EU. 0% WHT on qualifying corporate-to-corporate dividends (≥10% / ≥24 months) between Romanian and Cyprus subs.

— What we handle end-to-end

The full Cyprus transition stack

— 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

Romanian founders ask

Reviewed by

Nexora Editorial Standards Board

ICPAC-coordinated · Cyprus Bar partner-firm

Updated May 2026

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.

“Walked into the call confused, walked out with a 4-step plan, fixed-fee quote, and a Cyprus company set up two weeks later. No surprises on the bill.”

M. Kowalski

SaaS founder · Poland

Published with permission. Initials shown to preserve commercial-privacy preference.

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Dimension

Staying in Romania

Cyprus structure

Headline corporate tax

16% standard / 1-3% micro (≤€100k)

15% / ~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

Inheritance tax

0% (no inheritance/gift tax)

Combined social contributions

~25% employee + employer var

GHS 2.65% capped + SI on insurable up to €70,148

Effective rate on qualifying IP

16% (no IP Box)

~3% via IP Box

Cyprus structures for Romanian founders — post-micro-co reform

Why Romanian founders pick Cyprus

Cyprus 15% CIT + IP Box ~3% as the post-micro-co successor

Cyprus 0% SDC vs Romanian 10%+ dividend WHT

EU stability vs Romanian regulatory churn

RO-CY DTT (1981) + EU directive plumbing

Your Cyprus transition, end-to-end

Compared to staying in Romania

Romania–Cyprus regulatory map

Romania–Cyprus DTT (1981, revised)

Romanian micro-enterprise regime (narrowed 2024-2026)

Romanian ATAD-based corporate exit tax

EU Parent-Subsidiary Directive

The full Cyprus transition stack

Romanian founders ask

01Should I dissolve my Romanian SRL or keep it?

02Can I claim Cyprus IP Box on Romanian-developed software?

03What about Romanian VAT on cross-border services?

04Is the Cyprus 60-day rule available to a Romanian founder?

05What about Romanian wealth tax on luxury property?

06How does Cyprus-VAT registration work for the new entity?

07What about Romanian PFA (sole-trader) status?

08Does Cyprus have a Romanian-speaking practitioner network?

Related Cyprus services, tools & guides.

Cyprus structures for Romanian founders — post-micro-co reform

Why Romanian founders pick Cyprus

Cyprus 15% CIT + IP Box ~3% as the post-micro-co successor

Cyprus 0% SDC vs Romanian 10%+ dividend WHT

EU stability vs Romanian regulatory churn

RO-CY DTT (1981) + EU directive plumbing

Your Cyprus transition, end-to-end

Compared to staying in Romania

Romania–Cyprus regulatory map

Romania–Cyprus DTT (1981, revised)

Romanian micro-enterprise regime (narrowed 2024-2026)

Romanian ATAD-based corporate exit tax

EU Parent-Subsidiary Directive

The full Cyprus transition stack

Romanian founders ask

01Should I dissolve my Romanian SRL or keep it?

02Can I claim Cyprus IP Box on Romanian-developed software?

03What about Romanian VAT on cross-border services?

04Is the Cyprus 60-day rule available to a Romanian founder?

05What about Romanian wealth tax on luxury property?

06How does Cyprus-VAT registration work for the new entity?

07What about Romanian PFA (sole-trader) status?

08Does Cyprus have a Romanian-speaking practitioner network?

Related Cyprus services, tools & guides.