We use essential cookies to make our site work. With your consent, we may also use analytics cookies. Cookie Policy
Cyprus für deutsche Gründer · CIT 15% · Non-Dom 0%
German GmbH CIT approximately 15% federal + Gewerbesteuer approximately 14% + Solidaritätszuschlag = approximately 30% combined. Founder dividends: 26.375% Abgeltungsteuer. Cyprus alternative: 15% CIT (effective approximately 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.
Request a free 30-minute initial consultation.
— 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.
German exit tax can apply to qualifying shareholdings on departure. Instalments, security, reporting and any return relief are subject to the statutory conditions and application procedure. Obtain German advice before changing residence or transferring shares.
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 approximately €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).
A seven-day refund policy applies subject to the signed engagement terms. Government and third-party fees are excluded unless those terms state otherwise.
— 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.
Run the §6 AStG analysis with a German Steuerberater before departure. Liability, valuation, instalments, security, reporting and possible return relief depend on the statutory conditions and the taxpayer's facts.
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.
Review each Riester/Rürup contract and the German rules before changing contributions, withdrawing or transferring. Cyprus’s Article 20 election can apply 5% tax above €5,000 to qualifying foreign-service pension income, subject to the relevant treaty. It does not establish that a German pension can be transferred.
Send your enquiry for a no-obligation initial review.