Cyprus für deutsche Gründer · CIT 15% · Non-Dom 0%
German GmbH CIT ~15% federal + Gewerbesteuer ~14% + Solidaritätszuschlag = ~30% combined. Founder dividends: 26.375% Abgeltungsteuer. Cyprus alternative: 15% CIT (effective ~3% IP Box), Non-Dom 0% SDC for 17 years on dividends, EU member-state status protecting against German CFC look-through, Wegzugbesteuerung (§6 AStG) deferred under ATAD I for EU/EEA destinations including Cyprus.
Free 30-min consultation. Reply within 24h.
— WHAT YOU GET
Germany's CFC rules under §§7-14 Außensteuergesetz (AStG) more aggressively target low-tax third-country structures. Cyprus as an EU member benefits from the EU-substance defence — properly substanced Cyprus structures with genuine management + control + employees are typically NOT subject to German CFC re-attribution.
Germany's exit tax applies on departure of German tax-resident individuals with ≥1% shareholdings in corporations. Deemed disposal at market value, CGT ~27% combined. EU/EEA destinations (including Cyprus) qualify for AUTOMATIC INSTALMENT relief under §6 (5) AStG (post-2022 EU-compliance update) — payment over 7 years interest-free. Re-immigration within 12 years: tax refunded.
Cyprus Non-Dom regime exempts dividends from the Special Defence Contribution for 17 years from becoming Cyprus tax resident. For a founder distributing €500k/yr dividends, the saving vs German 26.375% Abgeltungsteuer is ~€132k/yr.
Cyprus 60-day rule is the EU's most flexible. For German citizens (EU), Yellow Slip (MEU1) is the standard residence permit — 4-6 weeks processing, no Pink Slip / visa required. Compatible with maintaining German business presence under SRT-equivalent tests.
— EVERYTHING INCLUDED
— PROCESS
Map your German exit + Cyprus arrival. Coordinate with your Steuerberater on the §6 AStG Wegzugbesteuerung filing + instalment-relief application.
Federal central register de-registration (Abmeldung), tax-residency cessation, year-of-departure return planning, German payroll / Sozialversicherung wind-down.
Cyprus Ltd 10 working days. Yellow Slip 4-6 weeks. Tax Residency Registration + Non-Dom declaration. TIC. Personal IR1 onboarding.
Annual Cyprus IR1 + IR4 (if Cyprus Ltd). Coordinate with German Steuerberater on the deferred Wegzugbesteuerung instalments + any residual German tax obligations (BZSt monitoring).
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 German founders run German GmbH (continuing German CIT + GewSt) + Cyprus HoldCo (collecting dividends 0% Cyprus WHT + Non-Dom 0% SDC on receipt). Structure carefully to satisfy DTT Article 4 tie-breaker + §AStG CFC defence.
Wegzugbesteuerung (§6 AStG) at ~27% combined CGT on the deemed-disposal gain is substantial. BUT the EU/EEA deferral under §6(5) AStG is automatic — no immediate cash outflow. Payment over 7 years interest-free for EU/EEA moves. Re-immigration within 12 years: refund. Plan with your Steuerberater early.
Germany respects DTT Article 4 tie-breakers but the BZSt monitors emigrants closely. Documentation matters: lease, utilities, employment in Cyprus, day-count log, substance file. Build it contemporaneously. Successful 1-2 year transitions are routine; sloppy departures get audited.
Non-Dom applies to Cyprus SDC on dividends, interest, rental REGARDLESS of source. German-source dividends from a German GmbH flowing to Cyprus-resident Non-Dom shareholder: 0% Cyprus SDC. German side may withhold 26.375% Abgeltungsteuer (Kapitalertragsteuer) unless treaty relief obtained — DE-CY DTT 1974 gives 5% on qualifying participations; recoverable via refund procedure.
Yes — spouse + minor children covered. Add €300 spouse / €200 per child to standard relocation pricing. Adult children need separate residence permits. Germany's family-reunification residency continues until exit.
German tax-advantaged pension contributions cease on tax-residency exit (case-specific). Existing accrued benefits remain. Cyprus QROPS-equivalent transfer is possible for some pension types — Cyprus 5% drawdown rate on >€3,420/yr saves vs German pension-drawdown rates.
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