Jurisdiction Profile
Cyprus Jurisdiction: EU Island with IP Box and Non-Dom Regime
Cyprus is one of the most discussed EU jurisdictions for tax-efficient corporate structures. The combination of the IP Box regime, non-dom status, and the 60-day rule makes the island particularly interesting for tech-driven entrepreneurs. Following the CIT increase to 15% in January 2026, the landscape has changed.
15%
Corporation Tax
~2.5%
Effective IP Box
17 years
Non-Dom Duration
Since 2004
EU Member
Fact-based assessment · Based in Malta since 2013
At a Glance
Cyprus offers a three-tier tax model with 15% corporation tax, an EU-compliant IP Box regime (effective rate of approx. 2.5%), and non-dom status. The 60-day rule allows for tax residency with minimal physical presence. However, following the CIT increase driven by OECD Pillar Two, the standard rate now sits at the global minimum level. For entrepreneurs without their own intellectual property, the tax advantage compared to other EU jurisdictions has diminished. Cyprus's greatest strength remains its IP Box regime, which ranks among the most attractive in the EU.
Eckdaten im Überblick
| Corporation Tax | 15%Since 1 January 2026 (previously 12.5%) |
| IP Box Regime | Effective approx. 2.5%80% exemption on qualifying IP income, nexus approach required |
| Non-Dom Regime | 17 years tax-freeForeign dividends, interest, and royalties; no minimum tax amount |
| Tax Residency | 60-day ruleCumulative: 60 days presence, no residency elsewhere, business activity in Cyprus |
| Income Tax (PIT) | Progressive up to 35%Tax-free allowance up to EUR 19,500; 50% exemption for first-time resident professionals |
| DTT with UK | ActiveComprehensive DTT network with over 65 agreements worldwide |
| Company Formation | 5 to 10 working daysOften possible entirely remotely; common law legal tradition |
| EU Member | Since 2004Access to the EU single market, free movement of capital |
What sets Cyprus apart as an EU jurisdiction
Over the past two decades, Cyprus has established itself as a serious EU jurisdiction for international entrepreneurs. The island combines a common law legal system in the English tradition with EU membership, a broad network of double tax treaties, and a tax system built on simplicity. Unlike many EU countries, Cyprus applies a flat-rate approach to corporation tax: 15% on profits, without complex refund mechanisms or special approvals.
For tech-driven companies, the IP Box regime is the main draw. Income from qualifying intellectual property - software, patents, trademarks - is taxed at an effective rate of approx. 2.5%. This is one of the lowest rates within the EU and follows the OECD-compliant nexus approach: the benefit only applies if the relevant research and development activity actually takes place in Cyprus.
The non-dom regime complements the system on a personal level: tax residents without Cypriot nationality or domicile pay no tax on foreign dividends, interest, and royalties. This exemption applies for up to 17 years and makes Cyprus particularly attractive for entrepreneurs receiving income from international holdings.
Add to this its geographical location in the eastern Mediterranean, making Cyprus a bridge between Europe, the Middle East, and North Africa. English is the standard language for business, and setting up a Cypriot company typically takes 5 to 10 working days.
The Cypriot tax system
The Cypriot tax system rests on three pillars that together form its competitive advantage: the corporation tax rate, the IP Box regime, and the non-dom status.
Since 1 January 2026, the corporation tax rate has been 15%. Cyprus raised the rate from the previous 12.5% to account for the EU-wide implementation of the OECD Pillar Two directive. Although the Pillar Two threshold applies to a consolidated annual turnover of EUR 750 million and most international entrepreneurs fall below this, Cyprus opted for a preventive adjustment. This means the standard tax rate is solid, but no longer a unique selling point within the EU.
The IP Box regime is Cyprus's true tax strength. Qualifying income from intellectual property is 80% exempt from taxation, resulting in an effective tax burden of approx. 2.5% given the 15% corporation tax rate. Qualifying assets include patents, copyrighted software, trademarks, and certain other intangible assets. The nexus approach is crucial here: the benefit is only available to the extent that the underlying research and development activity actually takes place in Cyprus or is carried out by the taxpayer themselves.
The non-dom status exempts tax residents from tax on foreign dividends, interest, and royalties - for up to 17 years after obtaining tax residency. There is no minimum tax amount and no lump-sum tax. Combined with a Cypriot holding company receiving dividends from international subsidiaries, this allows for a highly efficient structure.
Personal income tax follows a progressive scale up to 35%. Income up to EUR 19,500 is tax-free. For employees moving to Cyprus for the first time, there is a 50% exemption on income over EUR 55,000 - a strong incentive for qualified professionals.


Residence and tax residency
Cyprus's tax residency rules are among the most flexible in the EU. Alongside the traditional 183-day rule, there is the 60-day rule, which makes Cyprus particularly interesting for entrepreneurs who do not wish to live there full-time.
The 60-day rule requires the taxpayer to (a) spend at least 60 days per calendar year in Cyprus, (b) not spend more than 183 days in any other single country, (c) not be a tax resident in any other country, (d) run a business, hold shares in a company, or be employed in Cyprus, and (e) maintain an owned or rented property in Cyprus. All conditions must be met cumulatively.
In practice, the 60-day rule sounds tempting but is increasingly subject to strict scrutiny. HMRC applies the Statutory Residence Test (SRT) strictly. Genuine relocation must be demonstrated under the SRT ties tests. Without genuine substance on the ground - a home, family, social integration - there is a significant risk that your UK tax residency will remain unbroken. The 60-day rule establishes Cypriot residency, but it does not automatically sever your UK tax obligations.
No visa is required for EU citizens. Third-country nationals, including UK citizens post-Brexit, can obtain permanent residency through various programmes, such as the Cyprus Permanent Residency Programme (requiring a property investment of approx. EUR 300,000). However, the Cypriot residence permit does not grant the right to reside in other EU countries - it is valid only for Cyprus.
“Cyprus is a strong EU jurisdiction, especially for IP-driven business models. But the CIT increase to 15% has reshuffled the deck. If you don't bring your own intellectual property, Malta offers a more tax-efficient structure. We will look at the numbers together during our initial consultation and assess what truly fits your situation.”
Dr. Jörg Werner
Founder, Dr. Werner & Partners
Reality check: Daily life for international entrepreneurs
Cyprus offers a pleasant Mediterranean standard of living, and daily life is generally easy to organise for international entrepreneurs. The official languages are Greek and Turkish, but English is ubiquitous in business and everyday life. Most dealings with authorities, banking meetings, and contract negotiations are conducted in English. An English-speaking advisory infrastructure is well-established, though the international expat community is somewhat smaller than in Malta.
The property market has changed in recent years. Limassol, the preferred city for international business owners, has experienced a property boom. Monthly rents for high-quality apartments range between EUR 1,500 and EUR 3,000, and purchase prices have risen significantly, especially near the coast. Paphos and Larnaca offer more affordable alternatives with slightly less international infrastructure.
The banking situation requires an honest assessment. Following the 2013 financial crisis, where deposits over EUR 100,000 at Laiki Bank and Bank of Cyprus were partially bailed in, the sector has stabilised. The remaining banks are EU-regulated and subject to ECB supervision. Nevertheless, the banking sector is smaller and less internationally oriented than Malta's. For larger wealth or complex international structures, entrepreneurs occasionally report lengthy compliance checks during account opening.
Healthcare is provided through the GeSY system (General Healthcare System) introduced in 2019, which gives all residents access to public and private medical care. The quality in larger cities is good; for specialised treatments, many expats use private clinics or travel to Israel or Greece.
The infrastructure is solid: two international airports (Larnaca and Paphos), stable internet connections, and a pleasant climate with over 300 days of sunshine a year. The island is accessible via direct flights from major UK airports, with a flight time of approximately 4.5 hours from London.


Assessment: How Malta differs
As a law firm based in Malta, we provide an honest assessment of the differences between the two jurisdictions. Both have been EU members since 2004, both are located in the Mediterranean, and both offer low tax rates. However, their systems differ fundamentally in architecture.
The effective corporation tax burden is the most obvious difference: Cyprus taxes at a flat rate of 15%, while Malta achieves an effective rate of 5% through its 6/7 shareholder refund system. For companies without their own intellectual property - which includes the majority of trading, service, and consulting businesses - Malta is significantly more tax-efficient. Cyprus's IP Box regime (effective approx. 2.5%) can reverse this advantage for IP-driven business models, but it requires genuine research and development activity in Cyprus.
Regarding the non-dom regime, there is a crucial timeframe difference: Cyprus's exemption on foreign dividends and interest applies for a maximum of 17 years. After that, tax residents are subject to regular Cypriot taxation on their worldwide income. Malta offers a permanent alternative with its remittance basis: non-doms only pay tax on income remitted to Malta and on income arising in Malta. There is no time limit.
Malta's refund system is sector-neutral and does not require restriction to specific types of income. Whether trading, consulting, technology, gaming, or financial services - the effective 5% burden applies universally. Cyprus's lowest rates are tied to the IP Box regime and are therefore restricted to a specific income type.
On a personal level, Malta offers the Global Residence Programme (GRP) and similar schemes with a flat tax rate of 15% on foreign income remitted to Malta (minimum tax EUR 15,000). For entrepreneurs seeking a predictable personal tax burden, this can be an advantage over the Cypriot progressive scale.
We are not saying Malta is always the better choice. For IP-driven companies with their own research and development, Cyprus can be the more tax-attractive solution. However, for the majority of UK and international entrepreneurs without proprietary IP, Malta offers a lower effective tax burden and a more stable long-term structure.
The 2026 CIT increase: What it means for international entrepreneurs
On 1 January 2026, Cyprus raised its corporation tax rate from 12.5% to 15%. The adjustment was made in the context of the EU-wide implementation of the OECD Pillar Two directive, which mandates a global minimum tax of 15% for companies with a consolidated annual turnover exceeding EUR 750 million.
For most international entrepreneurs, turnover is well below this threshold. The Pillar Two rules are therefore not directly relevant to them. Nevertheless, Cyprus raised the rate preventively - to avoid being perceived internationally as a tax haven and to anticipate compliance with European directives.
The practical impact: anyone who previously calculated with 12.5% corporation tax in Cyprus must update their structural planning. The difference of 2.5 percentage points can be substantial for higher profits. At the same time, the tax gap with Malta has widened: Malta's effective 5% (after refund) is now compared against 15% in Cyprus - instead of the previous 12.5%.
For entrepreneurs already resident in Cyprus, little changes apart from the higher tax rate. The IP Box regime remains in place, continuing to offer an effective rate of approx. 2.5% on qualifying income. The non-dom status and the 60-day rule are also unaffected. However, anyone currently weighing up whether Cyprus or another EU jurisdiction is the better fit should factor the new tax burden into their overall calculation.
Our Process
Free Jurisdiction Analysis
In our initial consultation, we analyse your business model, income structure, and personal situation. We assess whether Malta or another EU jurisdiction is the better fit for your goals.
Tax Structuring
Based on the analysis, we develop the optimal corporate structure: holding company, operating company, refund planning, and personal tax residency in Malta.
Company Formation Malta
We handle the complete formation of your Maltese company: registration, articles of association, director appointment, and registry filing.
Bank Account and Infrastructure
Opening an account with a Maltese or international bank, setting up bookkeeping, and preparing for ongoing compliance requirements.
Ongoing Support
Annual financial statements, tax returns, refund applications, director duties, and ongoing advice on regulatory changes or structural adjustments.
Cyprus or Malta? We assess what fits your business model.
In a free initial consultation, we analyse your corporate structure and income types. 30 minutes, via video call or in person at our office in Malta.
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Frequently Asked Questions
Transparency matters to us. Here you will find answers to the most common questions on this topic.
Since 1 January 2026, the Cypriot corporation tax rate has been 15%. The rate was raised from the previous 12.5% to account for the OECD Pillar Two directive. The IP Box regime remains unaffected: qualifying IP income continues to be taxed at an effective rate of approx. 2.5%.
The 60-day rule allows you to become tax resident in Cyprus by spending just 60 days a year there. The prerequisites are that you are not tax resident in any other country, you run a business or hold shares in Cyprus, and you maintain a property on the island. All conditions must be met simultaneously. Important: while this establishes Cypriot residency, it does not automatically sever your UK tax obligations under HMRC's Statutory Residence Test.
The non-dom status in Cyprus is valid for a maximum of 17 years from the date of obtaining tax residency. During this time, foreign dividends, interest, and royalties are tax-free. After this period, you are subject to regular Cypriot taxation on your worldwide income. Malta's remittance basis offers a comparable exemption without a time limit.
Cyprus is particularly attractive for companies with their own intellectual property - software, patents, trademarks - that can benefit from the IP Box regime (effective approx. 2.5%). Entrepreneurs who live primarily on foreign dividends and passive income also benefit from the non-dom status. For trading and service companies without IP, Malta generally offers the more cost-effective structure with an effective 5% corporation tax rate.
We advise exclusively on Malta, but we understand the starting position of entrepreneurs weighing up Cyprus and Malta. In a free initial consultation, we analyse your business model and assess whether Malta is the right fit for your situation. If Cyprus is objectively the better choice - for example, with a pure IP model - we will tell you openly.
Next step
Cyprus or Malta? We assess what fits your business model.
In a free initial consultation, we analyse your corporate structure and income types. 30 minutes, via video call or in person at our office in Malta.

Dr Jörg Werner
Founder & Lawyer




and his team in Malta
