For Americanfounders & HNWIs
A Cyprus structure under US-citizen ownership: approximately 3% IP Box on qualifying software, EU domicile, US-CY DTT — coordinated with US tax counsel for FATCA, GILTI, CFC, and §877A considerations. Structured around your existing US obligations, not against them.
— The structural argument
Cyprus is in the EU; the US-Cyprus DTT (1984) provides reduced WHT on cross-border dividends, interest, royalties between qualifying entities. For US founders building international IP / SaaS / holding structures, Cyprus is one of the cleaner EU-domicile choices for US-investor-comfort.
Cyprus IP Box compresses qualifying-IP profit to approximately 3% effective tax. For US founders with international (non-US-customer) software revenue, structuring IP under a Cyprus HoldCo (with real Cyprus R&D substance and arm's-length contracts) materially compresses the non-US-side effective tax. US-side citizenship-based taxation continues unchanged.
We work alongside your US tax advisor on the GILTI / CFC / FATCA / Form 5471 workstream. The Cyprus structure is designed to be US-tax-compliant, not US-tax-avoidant. Realistic outcomes acknowledge US citizenship-based taxation; the goal is clean structural fit, not US-tax avoidance.
If/when the founder physically relocates from the US to Cyprus (and may eventually expatriate after §877A planning), the Cyprus 60-day rule (post-2026: 4 conditions) becomes available. The Cyprus residency + non-dom layer is a separate question from the US-citizenship layer — both run in parallel under US-side counsel.
— Day 0 → Day 90
American-specific workstream from first call to operational Cyprus structure.
Free 30-min call. We sketch the Cyprus structure, flag the US workstream (CFC analysis, GILTI exposure, FATCA reporting, possible check-the-box election), identify substance requirements. US tax counsel coordination from day one.
Cyprus Ltd formation in parallel with US-side CFC / GILTI / check-the-box analysis. US tax counsel decides on Form 8832 election timing. Cyprus directors + office substance set up.
Cyprus bank account opening (Bank of Cyprus / Hellenic / Astrobank — all FATCA-compliant). US FBAR / Form 8938 reporting infrastructure established for the new account. W-9 / W-8BEN / W-8BEN-E flows mapped.
Cyprus DTT residency certificate. US Form 5471 (Information Return for CFC) prep. Treaty-position documentation for the US-CY cross-border flows.
Structured IP transfer or exclusive licensing to Cyprus HoldCo. Modified-nexus methodology. US-side §367 transfer-pricing and §482 arm's-length analysis. US tax counsel signs off on the IP migration.
First Cyprus dividend / royalty under US-CY DTT. First Cyprus IP Box claim if qualifying. Year-1 US-side filings: Form 5471, FBAR, Form 8938, Schedule B disclosures. Annual compliance integrated US ↔ CY.
— Side-by-side
| Dimension | Staying in the US | Cyprus structure |
|---|---|---|
| Worldwide tax basis | Citizenship-based (US) | Residency-based (CY) — applies if founder relocates, US-citizenship continues |
| Headline corporate tax | 21% (US federal) + state | 15% (Cyprus, post-2026) |
| Effective rate on qualifying software IP | approximately 13.125% via FDII (subject to limits) | approximately 3% via IP Box (modified-nexus); US-side GILTI may apply if CFC |
| WHT on outbound dividends from CY | — | 0% on corporate-to-corporate; 0% SDC for non-dom individual (post-relocation) |
| EU + 65+ DTT network access | US has its own DTT network | Cyprus EU + 65+ DTTs + EU directives |
| FATCA reporting | Continues regardless of structure | Cyprus banks are FATCA-compliant; FBAR + Form 8938 from year 1 |
| GILTI exposure | — | Applies if Cyprus entity is CFC (>50% US-owned, ≥10% per US person); check-the-box may alter |
Indicative side-by-side. Your specific position depends on income mix, holdings, and the US-side exit-tax mechanics. Engagement-letter analysis required.
— Treaty & legal essentials
Reduced WHT on qualifying dividends, interest, royalties. Strict Limitation-on-Benefits provisions — substance + commercial purpose required.
If Cyprus entity is >50% US-owned (each US person ≥10%), GILTI applies — most non-routine Cyprus profits flow into US tax annually at approximately 10.5–13.125% effective. Check-the-box election can change the analysis.
US persons with Cyprus financial accounts: FBAR (FinCEN 114) if aggregate balance > $10k; Form 8938 at higher thresholds. Cyprus banks are FATCA-compliant — reporting to US Treasury is automated.
Renouncing US citizenship as a 'covered expatriate' (net worth ≥$2M etc.) triggers deemed sale of worldwide assets. Specialist US tax counsel essential — the Cyprus structure is independent of the §877A analysis until expatriation is complete.
— 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.
Continue exploring