Cyprus pour les fondateurs français · CIT 15% · Non-Dom 0%
French CIT 25% + flat-tax PFU 30% on dividends + IFI wealth tax pushes founder ETR easily north of 50%. Cyprus alternative: 15% CIT (effective ~3% on IP Box income), Non-Dom 0% Special Defence Contribution on dividends for 17 years, no wealth tax, EU member-state status protecting against French CFC look-through. Cyprus 60-day rule is more flexible than any French exit + return play.
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— WHAT YOU GET
French CFC rules (Article 209 B CGI) more aggressively pursue low-tax third-country structures (Cayman, BVI, UAE) than EU member states. Cyprus as an EU member is generally NOT treated as a 'privileged tax regime' under French CFC absent specific circumstances. Properly substanced Cyprus structures defend against French CFC reattribution.
France's exit tax applies on departure of French tax-resident individuals holding ≥50% participation OR shares valued >€800,000. Deemed disposal at market value, CGT ~30%. EU/EEA deferral (including Cyprus) is AUTOMATIC under ATAD I — no immediate payment. Tax is FORGIVEN if shares still held 2 years after move (extended to 5+ in some scenarios).
Cyprus Non-Dom regime (Article 8 ITL 118(I)/2002 + SDC Law 117(I)/2002) exempts dividends + interest + rental from the Special Defence Contribution for 17 years from becoming Cyprus tax resident. For founder dividend take-out — meaningful improvement over French 30% PFU.
Cyprus is the only EU member state with a 60-day tax-residency rule (vs France's 183-day standard). Yellow Slip (MEU1) is the EU citizen residence permit, 4-6 weeks processing. For French citizens (EU citizens), no Pink Slip / visa is required — Yellow Slip is the standard route.
— EVERYTHING INCLUDED
— PROCESS
We map your French exit + Cyprus arrival. Coordinate with your French tax adviser (avocat fiscaliste) on the Article 167 bis exit-tax deferral filing.
P85-equivalent French departure notification, French tax-residency-cessation declaration, year-of-departure French return planning, Cofidis / property-related French wind-downs.
Cyprus Ltd 10 working days (if business component). Yellow Slip 4-6 weeks. Tax Residency Registration + Non-Dom self-declaration. TIC. Personal IR1 onboarding.
Annual Cyprus IR1 + (if Cyprus Ltd) IR4. Coordinate with French side on any residual French tax obligations (deferred exit tax until 2 / 5 years post-departure when forgiveness triggers).
If your Cyprus Yellow Slip + Non-Dom declarations are not approved by the Civil Registry / Tax Department for any reason within our control, we refund 100% of our professional fee. Government disbursements pass through at cost.
— COMMON QUESTIONS
Yes. Many French founders run a French OpCo (continuing French CIT 25%) + Cyprus HoldCo (collecting dividends 0% Cyprus WHT + Non-Dom 0% SDC on receipt). Net: French side pays French CIT on operations; founder receives net dividend at Cyprus level with no further tax. Restructure carefully to satisfy DTT + CFC defence.
Article 167 bis CGI applies to shareholdings ≥50% OR > €800,000 in value. CGT ~30% applied on deemed disposal value at departure. EU/EEA deferral (including Cyprus) is automatic — no immediate cash outflow. Forgiveness in 2 years (sometimes 5+) if shares still held. Time your exit / structure carefully with French avocat.
France respects DTT tie-breakers under Article 4 OECD MTC. Once you successfully transition tax residency to Cyprus (via 60-day rule + permanent home in Cyprus + economic ties + day-count compliance), your TREATY-residency is Cyprus. Build the documentation file — French audits routinely test the substance of the transition.
French SCI continues paying French tax on French-source rental. Cyprus does not extraterritorially tax French immovable-property income (CYPRUS-FR DTT preserves source-state taxation on real property). Non-Dom does not apply to French-source income — only to Cyprus-or-foreign-source dividends, interest, rental flowing through Cyprus.
Yes — spouse + minor children covered under your Yellow Slip / Pink Slip with simple extension. Adult children require their own residence permit. We coordinate the family package. Add €300 / €200 per child to our standard relocation pricing.
Cessation of French tax residency typically ends mandatory French SECU contributions (case-specific). Cyprus social-insurance + GeSY apply once Cyprus tax-resident. Existing French pension rights remain. UK SIPP-equivalent Cyprus QROPS transfer possible for some French pension types.
Reply within 24 hours from a senior adviser. No obligation, no upfront fee.