What's the Spanish exit tax?

Article 95 bis LIRPF triggers when leaving Spain after 10+ years of residence (in last 15) AND holding shares worth >€4M OR >€1M representing >25% of an entity. Tax at savings rates (19-30%) on unrealised gains. Deferral available for EU/EEA moves (Cyprus is in scope) with reporting obligations. Pre-relocation valuation memo essential.

Cyprus 17-year non-dom vs Spain's Beckham Law — which is better?

Beckham Law: 24% flat on Spanish-source employment income up to €600k, 47% above, foreign-source generally exempt, 6 years duration. Cyprus non-dom: 0% SDC on dividends + interest, 17 years, no income cap. For dividend-heavy income, Cyprus is materially cheaper. For high Spanish-source employment income, Beckham may be flatter. Beckham years don't count toward the 10-year exit-tax residency clock — strategic for founders.

What is Spain's Solidarity Tax on Large Fortunes?

Spain's Solidarity Tax on Large Fortunes is 1.7%–3.5% on net wealth above €3M, in addition to regional wealth tax. Combined with high social contributions (~36% combined) and the new 30% CGT bracket above €300k, Spanish HNW friction is exceptional. Cyprus has no wealth tax + no inheritance tax + 0% SDC for non-doms.

How does the Spain-Cyprus DTT work?

ES-CY DTT signed 2013, in force 2014. Headline rates: dividends 0% (≥10% holding) / 5% otherwise, interest 0%, royalties 0%. Combined with the EU Parent-Subsidiary Directive, the corporate-to-corporate flows are exceptionally clean. One of the better-positioned EU-EU corridors for cross-border structuring.

What about Spanish residency-determination — when am I out?

Spanish tax residency is annual all-or-nothing — a Q3 departure still leaves the founder fully Spanish-resident for the year, including worldwide CGT on Cyprus-realised disposals. The 183-day count is calendar-year. Combined with the 'centre of economic interests' test, defending non-residency requires: ≤183 days Spanish presence, no Spanish habitual abode, primary economic ties shifted to Cyprus.

Will autonomous-community taxes still apply?

Autonomous-community surcharges (Madrid ~45%, Catalonia/Valencia ~50%+) apply to Spanish-source income while you remain Spanish-resident. After non-residency, Spanish-source income remains taxable in Spain at the relevant non-resident rate; foreign-source income shifts to Cyprus residency. Madrid's near-zero inheritance tax for direct family is preserved on Spanish-sited assets even after relocation; Cyprus adds 0% on top.

For Spanishfounders & HNWIs

Cyprus structures for Spanish founders — exit-tax-aware

From Spanish 25% CIT + 50% top PIT + 30% CGT + 1.7-3.5% Solidarity Tax to Cyprus 15% / 35% / 0%. Art. 95 bis exit-tax managed, Beckham Law structurally beaten by Cyprus 17-year non-dom for dividend-heavy founders.

€4M

ES exit threshold

ES-CY div WHT

CY CGT shares

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

— The structural argument

Why Spanish founders pick Cyprus

0% Cyprus SDC vs ~50% Spanish top + 30% CGT + 3.5% Solidarity

Cyprus non-dom: 0% on dividends + interest for 17 years. Spain stacks: top PIT 50%+, CGT up to 30% (above €300k from 2025), Solidarity Tax on Large Fortunes 1.7-3.5% on net wealth >€3M. Cyprus is structurally lighter across the income mix.

0% Cyprus CGT on shares + 0% inheritance tax

Cyprus CGT applies only to Cyprus-property; share sales are 0%. Cyprus inheritance tax was abolished. Spain: regional inheritance tax (Madrid near-zero, Asturias up to 32-34%) + property in Spain remains in Spanish scope.

ES-CY DTT (2014) — 0% qualifying dividends + 0% interest + 0% royalties

Among the cleanest EU-EU treaty positions in Cyprus's network. Combined with the EU Parent-Subsidiary Directive, the cross-border corporate flows operate at zero WHT in qualifying conditions.

Beckham years preserved — strategic for exit-tax timing

Beckham Law years don't count toward the 10-year Spanish-residency clock that triggers the €4M exit tax. Founders can use the Beckham window to time the Cyprus residency switch + IP/share migration before the exit-tax horizon.

— Day 0 → Day 90

Your Cyprus transition, end-to-end

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

Day 0–7: Tri-jurisdictional scope + Spanish counsel
Free 30-min call. We sketch the Cyprus structure, flag the §95 bis exit-tax workstream, identify Solidarity Tax + autonomous-community considerations. Spanish tax counsel engaged from day one.
Day 7–25: Cyprus company formation + Spanish exit-tax memo
Cyprus Ltd formation. Spanish-side §95 bis valuation memo for substantial shareholdings (if applicable). Pre-departure valuation locked.
Day 25–55: Cyprus banking + Spanish residency-cut prep
Cyprus bank account opening. Spanish-side documentation: §149 LIRPF residency-cut evidence (Cyprus property, day-count, primary economic interests).
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: IP / share migration if in scope
If Cyprus IP Box / HoldCo restructure: structured transfer with Spanish §95 bis exit-tax deferral election. Madrid wealth-tax exposure documented.
Day 60–120: Operational structure + first Spanish non-resident return
First Cyprus dividend (0% SDC under non-dom). First Spanish non-resident return for any residual Spanish-source income.

— Side-by-side

Compared to staying in Spain

Dimension	Staying in Spain	Cyprus structure
Headline corporate tax	25% standard / 15% new entities	15% (Cyprus, post-2026)
Top personal income tax	~50% (state + autonomous community)	35% top + 50% high-earner exemption
Capital gains on shares	19/21/23/27/30% (above €300k)	0% (only on Cyprus-property)
Wealth / Solidarity Tax	1.7-3.5% on net wealth > €3M	0% — no wealth tax
Exit tax	Art. 95 bis on shares > €4M / 25% holdings > €1M, 10+ yrs residency	—
Inheritance tax	Regionally administered (0-34%)	0% — abolished
Effective rate on qualifying IP	~25% (no comparable IP Box)	~3% via IP Box

Indicative side-by-side. Your specific position depends on income mix, holdings, and Spain-side exit-tax mechanics. Engagement-letter analysis required.

— Treaty & legal essentials

Spain–Cyprus regulatory map

Spain–Cyprus DTT (2013, in force 2014)

Modern treaty. 0% qualifying dividends, 0% interest, 0% royalties — among the cleanest EU-EU corridors in Cyprus's network.

Art. 95 bis LIRPF (Spanish exit tax)

Triggers on departure after 10+ years residency with shares > €4M or > €1M representing >25% of entity. EU-deferral available for Cyprus moves.

Beckham Law (Régimen Especial Trabajadores Desplazados)

Inbound regime: 24% flat on up to €600k, 6 years. Beckham years don't count toward exit-tax residency clock — strategic for founders timing structural moves.

Solidarity Tax on Large Fortunes + autonomous-community wealth tax

1.7-3.5% on net wealth > €3M (Solidarity) + regional wealth tax. Cyprus has neither.

— 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

Spanish 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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Cyprus structures for Spanish founders — exit-tax-aware

€4M

ES exit threshold

ES-CY div WHT

CY CGT shares

Dimension

Staying in Spain

Cyprus structure

Headline corporate tax

25% standard / 15% new entities

15% (Cyprus, post-2026)

Top personal income tax

~50% (state + autonomous community)

35% top + 50% high-earner exemption

Capital gains on shares

19/21/23/27/30% (above €300k)

0% (only on Cyprus-property)

Wealth / Solidarity Tax

1.7-3.5% on net wealth > €3M

0% — no wealth tax

Exit tax

Art. 95 bis on shares > €4M / 25% holdings > €1M, 10+ yrs residency

—

Inheritance tax

Regionally administered (0-34%)

0% — abolished

Effective rate on qualifying IP

~25% (no comparable IP Box)

~3% via IP Box

Cyprus structures for Spanish founders — exit-tax-aware

Why Spanish founders pick Cyprus

0% Cyprus SDC vs ~50% Spanish top + 30% CGT + 3.5% Solidarity

0% Cyprus CGT on shares + 0% inheritance tax

ES-CY DTT (2014) — 0% qualifying dividends + 0% interest + 0% royalties

Beckham years preserved — strategic for exit-tax timing

Your Cyprus transition, end-to-end

Compared to staying in Spain

Spain–Cyprus regulatory map

Spain–Cyprus DTT (2013, in force 2014)

Art. 95 bis LIRPF (Spanish exit tax)

Beckham Law (Régimen Especial Trabajadores Desplazados)

Solidarity Tax on Large Fortunes + autonomous-community wealth tax

The full Cyprus transition stack

Spanish founders ask

01Should I exit before or after a major share sale?

02Can I keep my Spanish SL and just move personally?

03What about Spanish autonomous-community surcharges after I leave?

04Beckham Law vs Cyprus non-dom — which order should I sequence?

05What about Spanish-sited real estate after relocation?

06How does Spanish 'centre of economic interests' test work?

07Can I keep Spanish freelance (autónomo) status from Cyprus?

08Does Cyprus have a Spanish-speaking practitioner network?

Related Cyprus services, tools & guides.

Cyprus structures for Spanish founders — exit-tax-aware

Why Spanish founders pick Cyprus

0% Cyprus SDC vs ~50% Spanish top + 30% CGT + 3.5% Solidarity

0% Cyprus CGT on shares + 0% inheritance tax

ES-CY DTT (2014) — 0% qualifying dividends + 0% interest + 0% royalties

Beckham years preserved — strategic for exit-tax timing

Your Cyprus transition, end-to-end

Compared to staying in Spain

Spain–Cyprus regulatory map

Spain–Cyprus DTT (2013, in force 2014)

Art. 95 bis LIRPF (Spanish exit tax)

Beckham Law (Régimen Especial Trabajadores Desplazados)

Solidarity Tax on Large Fortunes + autonomous-community wealth tax

The full Cyprus transition stack

Spanish founders ask

01Should I exit before or after a major share sale?

02Can I keep my Spanish SL and just move personally?

03What about Spanish autonomous-community surcharges after I leave?

04Beckham Law vs Cyprus non-dom — which order should I sequence?

05What about Spanish-sited real estate after relocation?

06How does Spanish 'centre of economic interests' test work?

07Can I keep Spanish freelance (autónomo) status from Cyprus?

08Does Cyprus have a Spanish-speaking practitioner network?

Related Cyprus services, tools & guides.