Cypr vs Wielka Brytania: Który jest odpowiedni dla Państwa działalności?

UK Position — April 2025

The UK abolished its resident non-domicile regime effective April 2025. A 4-year Foreign Income and Gains (FIG) exemption replaced it for new arrivals — but this is a temporary, transitional measure, not a permanent non-dom status. UK residents who previously relied on remittance basis are now subject to worldwide taxation.

Cyprus Non-Dom — Fully Available

Cyprus non-dom status provides 0% SDC (Special Defence Contribution) on dividends and interest income for up to 17 years. A 2.65% GeSY contribution applies on dividends and interest capped at €180,000/year. For UK entrepreneurs relocating and extracting dividends, this represents a dramatic reduction versus UK rates of up to 39.35%.

The 60-Day Rule

Founders who cannot commit to 183+ days in Cyprus can qualify under the 60-day rule: spend at least 60 days in Cyprus, maintain a Cyprus residence, and hold a Cyprus employment, directorship, or operate a Cyprus business. The 2026 reform relaxed the rule — it no longer requires non-residence in any other country, making it more accessible for internationally mobile founders.

Did the UK abolish the non-dom regime?

Yes. The UK abolished its resident non-domicile regime effective April 2025. In its place, the UK introduced a temporary 4-year Foreign Income and Gains (FIG) exemption for new arrivals — not a permanent non-dom status. For individuals already resident in the UK who lose non-dom protections, this means their worldwide income and capital gains are now taxable in the UK. Cyprus's non-dom regime (with 0% SDC on dividends for up to 17 years) remains fully available for qualifying individuals who establish Cyprus tax residency.

How do I establish Cyprus tax residency as a UK entrepreneur?

You can establish Cyprus tax residency via the 183-day rule (spending more than 183 days in Cyprus per calendar year) or the 60-day rule (spending at least 60 days in Cyprus, maintaining a Cyprus residence, and having Cyprus employment/directorship/business). The 60-day rule was relaxed in the 2026 reform — it no longer requires you to be non-resident in any other country.

Is there a double tax treaty between Cyprus and the UK?

Yes. Cyprus and the UK have a double tax treaty. This prevents double taxation on income earned in one country by residents of the other. The treaty is important for UK entrepreneurs with ongoing UK-source income while establishing Cyprus residency.

What about National Insurance / social insurance in Cyprus?

Cyprus does not have National Insurance as such. The equivalent contributions in Cyprus are: GeSY (National Health System) at 2.65% on employment income and 2.65% on passive income (dividends/interest) capped at €180,000; and Social Insurance at 8.8% on employment income capped at approximately €505/month. For self-employed individuals, different rates apply.

Can I keep my UK company and form a Cyprus company as a holding vehicle?

Yes. This is a common structure: a Cyprus holding company owns the UK operating subsidiary. Dividends from the UK subsidiary to the Cyprus holding company benefit from the UK-Cyprus DTT. The Cyprus holding company then distributes dividends to the individual shareholder (who as a Cyprus non-dom pays 0% SDC + 2.65% GeSY, versus UK dividend tax up to 39.35%). This requires proper substance in Cyprus and careful planning on UK exit tax and personal residence timing.