Cyprus pour les fondateurs belges · CIT 15% · Non-Dom 0%
Belgian CIT 25% + Innovation Income Deduction (IID) effective ~3.75-5% on qualifying IP. Cyprus alternative: 15% CIT (effective ~3% IP Box, lower than BE IID), Non-Dom 0% SDC on dividends for 17 years, EU shield against Belgian CFC, clean DTT residency transition. Belgium has no general individual exit tax (cleaner exit than DE/FR/IT).
Free 30-min consultation. Reply within 24h.
— WHAT YOU GET
Cyprus IP Box: 80% exemption → effective ~3% at 15% CIT. Belgian Innovation Income Deduction (IID, replaced Patent Income Deduction in 2017): 85% exemption → effective ~3.75-5% at 25% Belgian CIT. Cyprus marginally lower; both broadly competitive. Cyprus's lower headline rate + Non-Dom + EU substance picture wins for founder-led structures.
Belgian CFC rules (Article 185/2 ITC 1992) target low-tax structures. Cyprus as EU member benefits from EU-substance defence — properly substanced Cyprus structures with management + decisions in Cyprus + employees: typically NOT subject to Belgian CFC re-attribution.
Cyprus Non-Dom 0% SDC for 17 years vs Belgian 30% kapitaalbelasting on dividends. For €500k/yr founder dividend: BE ~€150k tax vs Cyprus €0 — saving ~€150k/yr.
Cyprus 60-day rule far more flexible than Belgian 183-day residency. Belgian citizens (EU) use Yellow Slip — 4-6 weeks. Maintain Belgian family + business presence under DTT tie-breaker tests.
— EVERYTHING INCLUDED
— PROCESS
Map your Belgian exit + Cyprus arrival. Coordinate with your Belgian belastingadviseur on the cross-border filings.
Belgian tax-residency cessation notification, INR-deregistration, year-of-departure return planning.
Cyprus Ltd 10 working days. Yellow Slip 4-6 weeks. Tax Residency Registration + Non-Dom declaration.
Annual Cyprus IR1 + IR4. Coordinate with Belgian belastingadviseur on residual obligations.
If your Cyprus Yellow Slip + Non-Dom declarations are not approved for any reason within our control, we refund 100% of our professional fee.
— COMMON QUESTIONS
Yes — Belgian BV / SRL continues paying CIT on Belgian operations. Cyprus HoldCo collects dividends 0% Cyprus WHT + Non-Dom 0% SDC. Belgian-side WHT 30% standard on portfolio dividends; relief under BE-CY DTT 1996 (10% on qualifying participations); reclaim procedure.
Belgium had a notional-interest-deduction system pre-2018 (since reformed). Cyprus's NID (Article 9B ITL) remains operational — provides notional-interest-deduction for new equity at the 10-yr bond + 5% premium (~8-9% currently). Cyprus NID is one of the few EU-wide equivalents preserved in 2026.
Yes — spouse + minor children covered with residence-permit extension.
Belgium has a securities-account tax (Taks op effectenrekeningen, 0.15% on portfolio >€1M). No general wealth tax. Cyprus has NO equivalent — no Cyprus wealth tax + no securities-account tax.
Belgian SPF Finances actively audits emigrating high-income individuals. Documentation matters: clean tax-residency cessation, Cyprus economic ties (lease, business activity), substance file. Successful transitions are routine with proper planning.
Reply within 24 hours from a senior adviser. No obligation, no upfront fee.