Cyprus dla polskich założycieli · CIT 15% · Non-Dom 0%
Polish CIT 19% standard / 9% small (≤€2M revenue) + 32% PIT on dividends. Cyprus alternative: 15% CIT (effective ~3% IP Box, materially below Polish IP Box 5%), Non-Dom 0% SDC on dividends for 17 years, EU member-state status protecting against Polish CFC, no Polish-equivalent exit tax (cleaner exit than DE/FR/IT/ES/NL).
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— WHAT YOU GET
Cyprus IP Box: 80% exemption on qualifying intangible profits = effective ~3% at 15% CIT. Polish Innovation Box: rate 5% on qualifying R&D-derived income. For typical SaaS / IT, Cyprus is ~2 percentage points lower effective. Cyprus also more permissive on copyrighted software scope.
Polish CFC rules (Article 24a CIT Law) target low-tax structures with substantial Polish-resident shareholders. Cyprus as EU member benefits from EU-substance defence — properly substanced Cyprus structures are typically NOT subject to Polish CFC re-attribution provided real management + decision-making in Cyprus.
Cyprus Non-Dom 0% SDC for 17 years vs Polish 19% PIT on dividends. For €500k/yr founder dividend: PL ~€95k tax vs Cyprus €0 — saving ~€95k/yr. Poland has no general individual exit tax (cleaner exit than DE/FR/IT/ES/NL).
Cyprus 60-day rule far more flexible than Polish 183-day SRT-equivalent. Polish citizens (EU) use Yellow Slip — 4-6 weeks. Maintain Polish family / business presence under DTT tie-breaker. Polish-Cyprus DTT preserves clean cross-border treatment.
— EVERYTHING INCLUDED
— PROCESS
Map your Polish exit + Cyprus arrival. Coordinate with your Polish doradca podatkowy on the residency-cessation filing.
Polish tax-residency cessation notification (PIT-Y / CIT specific filings), AIRE-equivalent (NIP-Y), year-of-departure 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. Coordinate with Polish doradca on residual Polish 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 — Polish sp. z o.o. continues paying CIT on Polish operations. Cyprus HoldCo collects dividends 0% Cyprus WHT + Non-Dom 0% SDC. Polish-side WHT 19% standard on portfolio dividends; relief under PL-CY DTT (5% on qualifying participations); claim via Polish tax-authority refund procedure.
Poland introduced an exit tax in 2019 (Article 30da PIT + Article 24f CIT) targeting individual + corporate emigrations with substantial business assets. Thresholds higher than in DE/FR/IT/ES/NL — affects only material business-owner emigrations. EU/EEA deferral available. Coordinate with Polish doradca.
Polish IP Box: 5% rate on qualifying intangible income (post-Modified Nexus Approach). Cyprus IP Box: 80% exemption → ~3% effective. Cyprus is materially lower. Polish IP Box also has narrower qualifying-IP scope (more restrictive on certain copyrighted software).
Yes — spouse + minor children covered with residence-permit extension. Adult children need separate permits.
Non-Dom applies to Cyprus SDC on dividends regardless of source. Polish-source dividends from a Polish sp. z o.o. flowing to Cyprus-resident Non-Dom: 0% Cyprus SDC. Polish-side WHT 19% standard; relief under PL-CY DTT 5%; reclaim procedure.
Reply within 24 hours from a senior adviser. No obligation, no upfront fee.