Cyprus per fondatori italiani · CIT 15% · Non-Dom 0%
Italian IRES 24% + IRAP 3.9% combined = ~28% on operating profit. Founder dividends: ~26% PIT. Cyprus alternative: 15% CIT (effective ~3% IP Box), Non-Dom 0% SDC on dividends for 17 years, EU member-state status protecting against Italian CFC look-through, Article 166 TUIR exit-tax deferred under ATAD I for EU/EEA destinations including Cyprus.
Free 30-min consultation. Reply within 24h.
— WHAT YOU GET
Italy's CFC rules under Article 167 TUIR target low-tax third-country structures. Cyprus as an EU member benefits from the EU-substance defence — properly substanced Cyprus structures with genuine management + employees are typically NOT subject to Italian CFC re-attribution.
Italy's exit tax under Article 166 TUIR applies to substantial individual shareholdings (typically ≥2% listed / ≥20% unlisted). CGT ~26%. EU/EEA deferral (including Cyprus) is available under ATAD I — 5-year instalment option without interest. Coordinate with your commercialista on the Italian-side filing.
Cyprus Non-Dom regime exempts dividends from the Special Defence Contribution for 17 years from becoming Cyprus tax resident. For founders distributing €500k/yr dividends, the saving vs Italian 26% PFL is ~€130k/yr.
Cyprus 60-day rule is the EU's most flexible. For Italian citizens (EU), Yellow Slip (MEU1) is the standard residence permit — 4-6 weeks processing, no Pink Slip / visa required. Compatible with maintaining Italian family + business presence under tie-breaker tests.
— EVERYTHING INCLUDED
— PROCESS
Map your Italian exit + Cyprus arrival. Coordinate with your Italian commercialista on the Article 166 TUIR exit-tax filing + ATAD instalment-relief.
AIRE (Anagrafe degli Italiani Residenti all'Estero) registration, Italian tax-residency cessation declaration, year-of-departure Italian return planning.
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 Italian commercialista on deferred exit-tax instalments + residual Italian obligations.
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 Italian founders run Italian SRL (continuing IRES + IRAP on Italian operations) + Cyprus HoldCo (collecting dividends 0% Cyprus WHT + Non-Dom 0% SDC on receipt). Structure carefully to satisfy DTT tie-breaker + Article 167 TUIR CFC defence.
Article 166 TUIR ~26% CGT on deemed-disposal gain for substantial shareholdings. EU/EEA deferral under ATAD I is available — 5-year instalments without interest. Plan with commercialista early; AIRE registration + tax-residency exit must be clean.
Italy respects DTT Article 4 tie-breakers but the Agenzia monitors emigrants closely. Documentation matters: AIRE registration, Cyprus lease, Cyprus utility bills, employment in Cyprus, day-count log, substance file. Successful 1-2 year transitions are routine.
Non-Dom applies to Cyprus SDC on dividends, interest, rental regardless of source. Italian-source dividends from an Italian SRL flowing to Cyprus-resident Non-Dom: 0% Cyprus SDC. Italian side withholds 26% as standard; relief under IT-CY DTT 1981 (1.5% on qualifying participations; specific procedures).
Yes — spouse + minor children covered. Add €300 spouse / €200 per child to standard relocation pricing. Italian family reunification preserved until exit.
Italian addizionale comunale + regionale (regional + municipal surtax) ceases on Italian tax-residency exit. Cyprus has no equivalent regional / municipal income surtax — total Cyprus PIT is the published 0-35% scale only.
Reply within 24 hours from a senior adviser. No obligation, no upfront fee.