Individuals can move to Cyprus, to take advantage of the tax efficiencies available, by spending at least 183 days in Cyprus without additional conditions.
For individuals with closer ties to Cyprus such as running/operating a business in Cyprus and/or being a director of a company which is tax resident in Cyprus, the ‘60 Day Tax Residency Rule’ might be of interest
1. The “60 Day” Tax Residency Rule
Since the implementation of the 60-day tax residency rule, a number of individuals have relocated to Cyprus to take advantage of the various tax benefits that are available.
Criteria to Meet the “60 Day” Tax Residency Rule
The “60 day” tax residency rule applies to individuals who in the relevant tax year:
reside in Cyprus for at least 60 days.
operate/run a business in Cyprus and/or are employed in Cyprus and/or are a director of a company which is tax resident in Cyprus. Individuals must also have a residential property in Cyprus which they own or rent.
are not tax resident in any other country.
do not reside in any other single country for a period exceeding 183 days in aggregate.
Days Spent In and Out of Cyprus
For the purpose of the rule, days “in” and “out” of Cyprus are defined as:
the day of departure from Cyprus counts as a day out of Cyprus.
the day of arrival in Cyprus counts as a day in Cyprus.
arrival in Cyprus and departure on the same day counts as a day in Cyprus.
departure from Cyprus followed by a return on the same day counts as a day out of Cyprus.
Please note that for the majority of jurisdictions you do not become tax resident if you reside there for less than 183 days a year. In certain jurisdictions, however, the number of days to be considered tax resident, is fewer than this. Professional advice should be taken.
2. Starting a Business in Cyprus as a Means of Relocation for Non-EU Nationals
Cyprus is an attractive jurisdiction for trading and holding companies, with access to all EU directives and an extensive network of double tax treaties.
To encourage new business to the island, Cyprus offers two temporary visa routes as a means for individuals to live and work in Cyprus:
Establishing a Cyprus Foreign Investment Company (FIC)
Individuals can establish an international company which can employ non-EU nationals in Cyprus. Such a company can obtain work permits for relevant employees, and residence permits for them and their family members. A key advantage is that after seven years, non-EU nationals can apply for Cyprus Citizenship.
Establishment of a Small/Medium Size Innovative Enterprise (Start-up Visa)
This scheme allows entrepreneurs, individuals and/or teams of people, from countries outside the EU and outside the EEA, to enter, reside and work in Cyprus. They must establish, operate, and develop a start-up business, in Cyprus. This visa is available for one year, with the option to renew for another year.
3. The Permanent Residence Permit
Individuals wishing to move to Cyprus can apply for a Permanent Residence Permit which is useful as a means to ease travel to EU countries and organise business activities in Europe.
Applicants must make an investment of at least €300,000 in one of the investment categories required under the programme, and prove they have an annual income of at least 50,000 (which can be from pensions, overseas employment, interest on fixed deposits, or rental income from abroad). If the holder of a Permanent Residence Permit resides in Cyprus, this may make them eligible for Cyprus citizenship by naturalisation.
4. Digital Nomad visa: non-EU nationals who are self-employed, salaried, or working on a freelance basis can apply for the right to live and work from Cyprus remotely.
Applicants must work remotely using information technology and communicate remotely with clients and employers outside Cyprus.
A Digital Nomad has the right to stay in Cyprus for a period of up to one year, with the right to renew for another two years. During the stay in Cyprus the spouse or partner and any minor family members, cannot provide independent work or engage in any kind of employment activity in the country. If they reside in Cyprus for over 183 days in the same tax year, then they are considered to be tax residents of Cyprus.
Each digital nomad must have; a salary of at least €3,500 per month, medical cover and a clean criminal record from their country of residence.
Currently the cap of the total amount of allowed applications has been reached and therefore this programme is currently unavailable.
Application for Cypriot Citizenship
The option is available to apply for Cypriot citizenship after a period of five years of residence and work within the Republic of Cyprus.
Additional Information
For further information about the attractive tax regime for individuals in Cyprus, and the visa options available, please contact Katrien de Poorter at the Dixcart office in Cyprus: advice.cyprus@dixcart.com.
Cyprus has uniquely positioned itself as a tax jurisdiction of choice for individuals. Various positive aspects of Cyprus Income tax legislation are available to individuals seeking a flexible and attractive tax regime.
What makes Cyprus a jurisdiction of choice for individuals is the non-domicile tax Regime which allows qualifying individuals to receive dividend and interest income exempt of income tax. In addition, individuals relocating to the island for the first time can benefit from reduced taxation on their employment income.
Day traders or individuals holding and managing their own investment portfolio can benefit extensively from the exemption of capital gains on the sale of equities.
The 60-day tax rule lends itself well for highly mobile individuals who travel extensively for work purposes and are not tied to one particular place of residence.
The tax benefits are further extended to individuals looking for a place to retire to.
Income Tax Reduction on Employment Income
On the 26th July 2022 the long-anticipated tax incentives for individuals were implemented. As per the new provisions of the income tax legislation, a 50% exemption for income in relation to first employment in Cyprus is now available for individuals with annual remuneration in excess of €55,000 (previous threshold EUR 100.000). This exemption will be available for a period of 17 years.
Cyprus Tax Residency in 60 Days
An individual can become Cyprus tax resident in 60 days. This rule is applicable to individuals who do not spend more than 183 days in Cyprus or in any other jurisdiction.
The “60 day rule” applies to individuals who in the relevant tax year reside in Cyprus for at least 60 days, operate/run a business in Cyprus and/or are employed in Cyprus and/or are a director of a company which is tax resident in Cyprus.
Individuals must also have a residential property in Cyprus which they own or rent and not be tax resident in any other country. The individual must not reside in any other single country for a period exceeding 183 days in aggregate.
Non-domicile Status
Individuals can acquire Cyprus tax residency after having complied with spending either 183 days or 60 days in Cyprus. Please contact the Dixcart office in Cyprus for further details about these two alternatives: advice.cyprus@dixcart.com
The Non-domicile tax regime is particularly interesting for individuals whose main source of income is either dividend income or Interest Income. In addition individuals can take advantage of the exemption of taxation on capital gains.
UK nationals and Other Non-EU Resident Applicants
Due to Brexit, UK nationals are now considered as non-EU nationals and therefore need to follow the same application procedure as other non-EU nationals:
Non-EU nationals and the Permanent Residence through Investment Programme
In order to acquire a Permanent Residence Permit the non-EU national needs to make an investment of at least €300,000, (excluding VAT) in one of the following investment categories: residential real estate, other types of real estate such as offices, shops, hotels or investment in the share capital of a Cyprus company, or in units of a Cyprus Investment Organization of Collective Investments (type AIF, AIFLNP, RAIF). In addition, evidence of a secure annual income of at least €50,000 must be provided. This required annual income, increases by €15,000 for the spouse and €10,000 for every minor child.
Non-EU Nationals and Temporary Residence through a Foreign Interest Company
A Foreign Interest Company is an international company, which, subject to meeting specific criteria, can employ non-EU national employees in Cyprus.
This programme enables employees and their families to gain residence and work permits under favourable terms. The main requirements enabling an international company to qualify as a Foreign Interest Company are all third country shareholder(s) must own more than 50% of the total share capital of the company, and there must be a minimum investment of €200.000 into Cyprus by these third country shareholder(s). This investment can be used at a later date, to fund future expenses incurred by the company when it is established in Cyprus.
Temporary residence on a visitor basis without the right to undertake any form of employment.
Non-EU nationals can acquire a temporary residence permit based on a visitor visa, which can be renewed for a period of up to 10 years.
This type of residence does not allow the undertaking of any form of employment.
This basis of residence is most suitable for pensioners wishing to establish themselves in Cyprus and enjoy the advantageous tax regime applicable to foreign pensions. Please contact the Dixcart office in Cyprus for more details: advice.cyprus@dixcart.com.
Additional Information
For additional information about the attractive tax regime for individuals in Cyprus, please contact: Katrien De Poorter at the Dixcart office in Cyprus: advice.cyprus@dixcart.com.
On 19 July 2023, the Portuguese Parliament voted on the final version of the new Portuguese Golden Visa legislation.
The programme will continue for a number of non-real estate investments, but there are some major changes.
Existing Holders of Golden Visas and Pending Applications
For investors who already have Golden Visas or who have pending applications, the new legislation provides clarity.
Pending applications will be converted into Entrepreneur Permits (D2 Visas). The minimum stay requirements and the validity period of the new residency permits will remain the same.
Five years of legal residency under the D2 Visa will still grant the right to apply for Portuguese citizenship.
What Happens Next?
The new law is now in the President’s hands.
He has 20 days to decide whether to ratify the legislation or return it to Parliament for amendments. It is not possible to say when the new law will enter into force, but it is likely to happen soon.
What Will the Criteria Be for New Investors?
For future investors, the new legislation brings some new opportunities.
The following investments will each qualify for the Golden Visa:
The creation of ten jobs; OR
Capital transfer of a minimum €500,000 for research activities, carried out by private or public scientific research institutions, integrated in the national scientific and technological system; OR
Capital transfer of a minimum €250,000 for investment in supporting artistic productions, reflecting the national cultural heritage. Such an investment can be, through; central and/or peripheral direct administration services, public institutes, entities that integrate the business and public sector, public foundations, private foundations with public utility status, inter-municipal entities, entities that are part of the local business sector, municipal associative entities and public cultural associations; OR
Capital transfer of a minimum €500,000, for the acquisition of shares in a non-real estate collective investment entity, incorporated under Portuguese law. At the time of the investment, maturity must be at least five years in the future, and at least 60% of the value must be invested in commercial companies with headquarters in Portugal; OR
Capital transfer of a minimum €500,000 for the incorporation of a commercial company, with headquarters in Portugal, combined with the creation of five permanent jobs. Alternatively a minimum €500,000 can be added to the capital of an existing commercial company, with headquarters in Portugal. This must be combined with the creation of at least five permanent jobs, or the maintenance of at least ten jobs, with a minimum five permanent employees, for a minimum period of three years.
Summary
The new legislation provides some clarity for investors, with further details still awaited. Specifically, the Portuguese Government needs to amend the regulations to explain how the new law will be applied.
Additional Information
If you would like additional information or advice as to what action you should take, please reach out to our offices in Portugal (Lisbon and Madeira) for assistance: advice.portugal@dixcart.com.
Cyprus is a hidden European gem in terms of the opportunities and benefits available to individuals and corporates, moving there on a permanent basis and/or establishing residency through the ’60 Day Tax Residency Rules’.
EU and Non-EU Individuals
For non-EU nationals there are various programmes for individuals to enable them to move to Cyprus, with one option being to establish a company in Cyprus. EU nationals are free to move to Cyprus, as Cyprus is in the EU.
The ‘60 Day Tax Residency Rule’ is a route for EU and non-EU nationals, to optimise the tax efficiencies available from Cyprus, without needing to reside there more than 60 days a year.
We will start by looking at the tax benefits available to individuals and to corporates.
Tax Benefits Available to Individuals
What are the Advantages of Becoming Cyprus Tax Resident?
Cyprus non-domicile status can be an effective means to optimise personal wealth planning. The advantages of becoming Cyprus tax resident, an option for individuals not previously tax resident in Cyprus, include the following:
Non-Domicile Status
The non-domicile tax regime is particularly interesting for individuals whose main source of income is either dividend or interest income, as these sources of income are not taxed in Cyprus.
Individuals can also take advantage of the exemption from taxation of capital gains, other than on the sale of immoveable property in Cyprus.
In addition, there is an exemption from taxation on capital sums received from pensions, provident and insurance funds as well as several other tax advantages, including; a low rate of tax on foreign pension income, and no wealth or inheritance taxes in Cyprus.
The zero tax benefits, mentioned above, are enjoyed even if the income has a Cyprus source and/or is remitted to Cyprus.
Employment Income Tax Exemption
There is a 50% exemption from taxation, for income for ‘first time’ employment in Cyprus, for individuals with an annual remuneration income of over €55,000.
This exemption is available for a period of up to 17 years.
Tax Exemption on Income from Employment Outside Cyprus
Individuals who are employed outside of Cyprus, for more than 90 days in aggregate in a tax year, by a non-Cyprus tax resident employer or foreign permanent establishment of a Cyprus tax resident employer, are exempt from income tax on this income.
Tax Benefits Available to Companies
Corporate Tax Rate
Cypriot companies enjoy a 12.5% rate of tax on trading, and a zero rate of capital gains tax. In addition, Cyprus tax resident companies and Cyprus permanent establishments (PEs) of non-Cyprus tax resident companies, are entitled to a Notional Interest Deduction (NID), on the injection of new equity used to generate taxable income.
NID
NID is deducted from taxable income. It cannot exceed 80% of the taxable income, as calculated prior to the NID, arising from the new equity. A company could achieve an effective tax rate as low as 2.50% (corporate tax rate 12.50% x 20%). Please contact the Dixcart office in Cyprus for further information: advice.cyprus@dixcart.com
Increased Tax Deduction for Research and Development Expenses
Eligible research and development expenses can be deducted from taxable income equivalent to 120% of the actual spend.
Starting a Business in Cyprus as a Means of Relocation for Non-EU Nationals
Cyprus is an attractive jurisdiction for trading and holding companies and offers a number of tax incentives, as detailed above.
To encourage new business to the island, Cyprus offers two temporary visa routes as a means for individuals to live and work in Cyprus:
Establishing a Cyprus Foreign Investment Company (FIC)
Individuals can establish an international company which can employ non-EU nationals in Cyprus. Such a company can obtain work permits for relevant employees, and residence permits for them and their family members. A key advantage is that after seven years, third country nationals can apply for Cyprus Citizenship.
Establishment of a Small/Medium Size Innovative Enterprise (Start-up Visa)
This scheme allows entrepreneurs, individuals and/or teams of people, from countries outside the EU and outside the EEA, to enter, reside and work in Cyprus. They must
establish, operate, and develop a start-up business, in Cyprus. This visa is available for one year, with the option to renew for another year.
For further information about the attractive tax regimes available to individuals and companies in Cyprus, please contact Robert Homem or Katrien de Poorter at the Dixcart office in Cyprus: advice.cyprus@dixcart.com
The Limited Time Offer, including a reduced donation amount which was previously available from 1 January 2023 to the end of June 2023, has been extended until 31 January 2024. Now is the time to take action.
On 29 June 2023, Michael Martin, Head of the St Kitts and Nevis Citizenship by Investment Unit (CIU), made the following announcement:
“We have received an overwhelming response and demand for our Sustainable Growth Fund investment option through the Limited Time Offer and felt that we had to extend the offering for another seven months, until 31 January 2024. International investors continue to see the value of the world’s first and finest Citizenship by Investment Programme and this proves it”.
What are the Details of the Limited Time Offer (LTO)?
The Sustainable Growth Fund (SGF) remains the quickest and easiest route to alternative citizenship in St Kitts & Nevis, with a main applicant being able to acquire alternative citizenship by contributing only US$125,000 to the SGF and receiving approval ‘in principle’, within 60 days of acknowledgement by the CIU of submission of the application.
Under the terms of the LTO, the minimum SGF contributions are as follows:
• Single applicant – US$125,000
• Main applicant and a spouse – US$150,000
• Main applicant and up to three dependants – US$170,000
• Each additional dependant under 18 – US$10,000
• Each additional dependant over 18 – US$25,000
These costs are US$25,000 less for each of the categories of; main applicant, main applicant and spouse, and a family of four, compared to the contribution costs prior to the LTO, and as from the end of January 2024.
What are the Benefits of St Kitts & Nevis Citizenship?
There are several benefits of St Kitts & Nevis citizenship, with a number of the most important advantages being detailed below:
Visa-free travel to more than 150 countries, including; the UK, Schengen Area, and Canada. This can be especially beneficial for individuals who want to travel freely and explore the world without the complication of applying for visas.
Another advantage of St. Kitts & Nevis citizenship by investment is that it offers a high standard of living in a beautiful setting. The country boasts stunning beaches, lush rainforests, and a warm, tropical climate. The locals are known for their friendly, welcoming nature, and the country has a rich cultural heritage that is celebrated through music, dance, and art.
In addition, St. Kitts & Nevis is politically stable and has a strong economy, making it a safe and secure destination for investors. The government has implemented measures to attract foreign investment, such as offering tax incentives and promoting business development. As a result, the country has seen steady economic growth in recent years.
Finally, Nevis Citizenship by Investment provides access to a global community of investors, which can be a valuable resource for business owners and entrepreneurs looking to expand their networks.
Additional Information
The Dixcart office in Nevis has extensive experience in assisting individuals to successfully apply for St Kitts & Nevis citizenship.
Please contact John Mellor for additional information regarding the benefits of this LTO and how you can make an application under the St Kitts & Nevis CBI programme: advice.nevis@dixcart.com.
In May 2023, Cyprus made a number of amendments to the Cyprus Permanent Residence Programme (PRP) with regards to; the secure annual income of the applicant, the criteria for eligible dependant family members, and requirements in relation to the property (permanent residence) of the applying family. In addition, ongoing obligations have been added in terms of maintaining the investment, following its approval.
As a reminder, we list here the various investment options that are available to acquire Permanent Residence in Cyprus.
Investment Options Available:
A. Purchase residential real estate worth at least €300,000 (+VAT) from a development company.
OR
B. Investment in real estate (excluding houses/apartments): Purchase of other types of real estate such as offices, shops, hotels or related estate developments or a combination of these with a total value of €300,000. The purchase of interest can be the result of a resale.
OR
C. Investment in the share capital of a Cyprus Company, with business activities and personnel in the Republic: Investment worth €300,000 in the share capital of a company registered in the Republic of Cyprus, based and operating in the Republic of Cyprus and having a proven physical presence in Cyprus, and employing at least five (5) people.
OR
D. Investment in units as recognised by the Cyprus Investment Organization of Collective Investments (types of AIF, AIFLNP, RAIF): Investment worth €300,000 in units of Cyprus Investment Organization Collective Investments.
Additional Requirements
The funds of the investment must come from the Bank Account of the main applicant or his/her spouse, provided that the spouse is included as a dependant in the application.
For the submission of the application the amount of at least €300,000 ( + VAT) must be paid to the Developer regardless of the completion date for the property. Relevant receipts must accompany the submission of the application.
Provide evidence of a secure annual income of at least €50,000
(increased by €15,000 for the spouse and €10,000 for every minor child).
This income can come from; wages for work, pensions, stock dividends, interest on deposits, or rent. Income verification,must be the individual’s relevant tax return declaration, from the country in which he/she declares tax residence.
In the situation where the applicant wishes to invest as per investment option A, the income of the spouse of the applicant may also be taken into consideration.
In calculating the applicant’s total income where he or she chooses to invest as per the options B, C or D above, his/her total income or part of it may also arise from sources originating from activities within the Republic, provided that it is taxable in the Republic. In such cases, the income of the spouse/husband of the applicant may also be taken into consideration.
Other Terms and Conditions
All family members must provide a Health Insurance Certificate for medical treatment covering inpatient and outpatient care in case they are not covered by GEsy (The Cypriot National Health Care System).
The property to be used as the investment for the submission of the application and to be declared as the permanent residence of the family, must have sufficient bedrooms to satisfy the needs of the main applicant and his/her dependent family.
A clean criminal record issued by the authorities of the country of residence and country of origin (if different), need to be provided upon submission of the application.
The immigration permit does not allow the applicant and his/her spouse to undertake any form of employment in Cyprus and holders of the immigration permit must visit Cyprus once every two years. PRP holders are however permitted to own Cyprus companies and receive dividends.
The applicant and his spouse/husband will certify that they do not intend to be employed in the Republic with the exception of their employment as Directors in a Company in which they have chosen to invest within the framework of this policy.
In cases where the investment does not concern a Company’s share capital, the applicant and/or his spouse may be shareholders in Companies registered in Cyprus and the income from dividends in such companies shall not be considered as an obstacle for the purposes of obtaining the Immigration Permit. They may also hold the position of Director in such companies without pay.
In the cases where the applicant chooses to invest under any of options B, C, D, he/she must present information regarding the place of residence for himself and family members in the Republic (e.g. property title deed, sales document, rental document).
Family Members
As dependent family members, the main applicant can include ONLY; his/her spouse, minor children and adult children up to the age of 25 who are university students and financially dependent on the main applicant. No parents and/or parents-in-law are accepted as dependent family members. The annual secured income increases by €10,000 per adult child studying at a university up to the age of 25. The studying adult children must submit an application for a temporary residence permit as a student which can be converted to an Immigration Permit upon finalization of their studies.
HIGHER VALUE INVESTMENT TO INCLUDE ADULT CHILDREN
An Immigration Permit may also be granted to adult children of an applicant who are not financially dependent, on the understanding that a higher value investment is made. The market value of the investment of €300,000 should be multiplied according to the number of adult children, claiming the same investment for the purposes of obtaining an Immigration Permit. For example, where the applicant has one adult child, the investment should be worth €600,000, if he has two adult children the investment value should be €900,000 gross.
Benefits
Actual residence in Cyprus may lead to eligibility for Cyprus citizenship by naturalisation.
Ongoing requirements after approval of the application
Once the application is approved by the Civil Registry and Migration Department, the applicant must submit evidence, on an annual basis, to prove that; he/she has maintained the investment, that he/she maintains the required income determined for him and his family, and that he and his family members are holders of a health insurance certificate, in case they are not beneficiaries of GHS/GESY (General Health System). In addition, the applicant and his adult family members are required to provide an annual certificate of a clean criminal record from their country of origin, as well as from their country of residence.
Additional Information
If you would like any additional information regarding the Cyprus Permanent Residence Programme and/or the recent changes to it, please speak to our office in Cyprus: advice.cyprus@dixcart.com
Property in Portugal has recorded double digit percentage growth in various sectors, listed by numerous real estate service companies, in recent years, and the expectation is that this will continue – with an increased demand and reduced supply than previously seen.
It is an interesting misconception that property prices are driven predominantly by the Golden Visa program – in actual fact, the Portuguese Golden Visa accounts for an insignificant portion of property purchases, when considered in comparison to total property purchases in Portugal.
What are the Factors Affecting Property Prices in Portugal?
Various factors in Portugal are influencing the increase in property prices, including:
Portugal is the new acclaimed California, the new European Silicon Valley;
Portugal is ranked one of the best places to live and work in the world;
It is an attraction magnet for digital nomads;
Portugal offers a 10-year tax holiday for the affluent;
Property has offered favourable investment opportunities over recent years and that is no different now.
Taxation of Property in Portugal
The importance of understanding the related tax consequences of holding property in Portugal is vital.
Dixcart have generated an Article that provides a comprehensive guide to the various taxes that need to be considered:
Please see below the types of taxes and the other matters that you should carefully consider:
When is Stamp Duty Applicable?
Stamp Duty on the Purchase of a Property
Property Transfer Tax
Annual Municipal Property Tax (IMI)
What Tax Consequences are Applicable Upon the Sale of a Property?
What are the Tax Consequences for My Rental Income?
What Inheritance Tax Implications Exist for Property (or is it Stamp Duty that Applies)?
What is the Preferred Structure to Hold Property in Portugal?
Dixcart is generating two additional guides regarding holding property in Portugal and the relevant taxes: the first relates specifically to the taxes in connection to property purchases and sales, while the second will cover the tax obligations in relation to rental income generated through property held in Portugal.
Other Considerations
Other important matters to take into account for non-resident individuals are; the specifics of the relevant double taxation treaty between Portugal and the country that the individual is resident in, as well as the local laws and regulations applicable in the country of tax residence.
A typical example of this for a UK resident, is the fact that UK tax residents also pay tax on the gain from the Portuguese property in the UK, however, under the double taxation treaty, any tax paid in Portugal may be credited against the tax due in the UK.
Why is it Important to Engage with Dixcart?
It is not just the Portuguese tax considerations on properties, but also the impact from where you may be tax resident and/or domiciled, that need to be considered. Although property is typically taxed at source, double taxation treaties and double tax relief need to be considered, as indicated above.
A typical example is the fact that UK residents will also pay tax in the UK and this will be calculated based on UK property tax rules, which may be different to those in Portugal. They are likely to be able to offset the Portuguese tax actually paid against the UK liability to avoid double taxation, but if the UK tax is higher, further tax will be due in the UK. Dixcart will be able to assist in this regard and to help make sure you are aware of your obligations and filing requirements.
How Else Can Dixcart Assist?
Dixcart Portugal have a team of experienced professionals who can assist with various aspects regarding your property; efficient tax planning, legal support (for the sale or purchase of a property), accounting and tax support and the incorporation and maintenance of companies.
Further to this, if you would like a deemed tax calculation to be performed, or any additional information, please reach out to our offices in Portugal for this information: advice.portugal@dixcart.com
Surrounded by the bright blue waters of the Mediterranean Sea, Cyprus has always been an enticing location for high-net-worth individuals considering relocation. It is a member of the EU and therefore well positioned for those who seek global mobility and ease of travel across Europe, as well as the Middle East and Africa.
English is widely spoken in Cyprus, having been part of the Roman Empire and a British colony for many years, however traditions run deep through the island’s villages, with each enjoying a variety of cultural influences to share with newcomers.
Cyprus has a Mediterranean climate. Whilst small, the island is an archaeological and natural haven, with stunning seaside villages and beaches. It is also home to a large community of expats who have relocated to Cyprus to enjoy the benefits that the island, and the tax regime offers.
Cyprus offers the following lifestyle benefits:
A Mediterranean lifestyle and peaceful, friendly community
A good work-life balance
Excellent transport links
A diverse range of amenities
Low cost of living
Excellent private and state healthcare sectors
A large expat community
A high quality of education, there is the option for private education (English curriculum) or public education, as well as several international Universities located on the island
Attractive tax benefits
Cyprus Offers a Range of Interesting Tax Incentives for Individuals
Many high-net-worth individuals relocate to Cyprus due to its advantageous non-domicile tax regime, whereby individuals who were not previously tax resident can apply for non-domicile status.
Cypriot non-domiciles benefit from a zero rate of tax on; interest, dividends, and capital gains (apart from capital gains derived from the sale of immovable property in Cyprus), and capital sums received from pension, provident and insurance funds.
These zero tax benefits are enjoyed even if the income has a Cyprus source or is remitted to Cyprus. There are several other tax advantages, including a low rate of tax on foreign pensions, and there are no wealth or inheritance taxes in Cyprus.
Options for Relocating: Permanent Residence and Temporary Residence Permits
Individuals wishing to move to Cyprus can apply for a Permanent Residence Permit which is useful as a means to ease travel to EU countries and organise business activities in Europe.
Applicants must make an investment of at least €300,000 in one of the investment categories required under the programme, and prove they have an annual income of at least €50,000 (which can be from pensions, overseas employment, interest on fixed deposits, or rental income from abroad).
If the holder of a Permanent Residence Permit resides in Cyprus, this may make them eligible for Cyprus citizenship by naturalisation.
Alternatively, a temporary residence permit can be obtained by establishing a foreign investment company (FIC). Through this kind of international company, work permits can be obtained for relevant employees, and residence permits for them and family members. Another key advantage is, again, that after residing for seven years in Cyprus, within any ten-calendar year period, third country nationals can apply for Cyprus citizenship.
Moving to Cyprus to take up Employment.
It is common for high-net-worth individuals to relocate to Cyprus for employment purposes. If the Permanent Residence Permit is not the right route for you and/or your family, Cyprus offers several alternate ways to live and work in Cyprus:
Business Facilitation Unit: visas for highly skilled third country nationals – the Ministry of Finance announced in 2022, that they are introducing the Business Facilitation Unit to assist highly skilled third country employees with a minimum gross salary of €2,500 per month, to gain work permits in Cyprus. These permits will last up to three years.
Digital Nomad visa: non-EU nationals who are self-employed, salaried, or on a freelance basis can apply for the right to live and work in Cyprus remotely, for up to one year. The visa can be renewed for another two years.
Why Relocate to Cyprus for Work?
Personal taxation benefits:
A tax exemption, of 50% of employment income, is available to an individual employed in Cyprus who was resident outside of Cyprus before he/she commenced employment in Cyprus. The exemption applies for a period of seventeen years starting from the first year of employment in Cyprus, provided that employment income exceeds €55,000 per year.
Cyprus has more than 65 tax treaties that provide for zero or reduced withholding tax rates on; dividends, interest, royalties, and pensions received from abroad. In addition, lump sums received as a retirement gratuity, are exempt from tax.
A Cypriot tax resident receiving pension income from abroad, can choose to be taxed at a flat rate of 5%, on amounts exceeding €3,420 per year.
Starting a Business in Cyprus as a Means of Relocation
The reputation of Cyprus as an international financial centre has grown significantly over recent years. Cyprus is an attractive jurisdiction for trading and holding companies and offers a number of tax incentives.
In order to encourage new businesses to the island, Cyprus offers two temporary visa routes as a means for individuals to live and work in Cyprus:
Establishing a Cyprus Foreign Investment Company (FIC): individuals can establish an international company which can employ non-EU nationals in Cyprus. Such a company can obtain work permits for relevant employees and residence permits for them and their family members. A key advantage is that after seven years, third country nationals can apply for Cyprus Citizenship.
Establishment of a small and medium sized Innovative Enterprise (Start-up visa): this scheme allows entrepreneurs (individuals or a team), from countries outside the EU and outside the EEA, to enter, reside and work in Cyprus in order to; establish, operate, and develop a start-up business. This visa is available for one year, with the option to renew for another year.
Corporate Tax Benefits:
Cypriot companies enjoy a 12.5% rate of tax on trading, and a zero rate of capital gains tax. In addition, Cyprus tax resident companies and Cyprus permanent establishments (PEs), of non-Cyprus tax resident companies, are entitled to a Notional Interest Deduction (NID), on the injection of new equity used to generate taxable income.
NID is deducted from taxable income. It cannot exceed 80% of the taxable income, as calculated prior to the Notional Interest Deduction, arising from the new equity. A company could achieve an effective tax rate as low as 2.50% (income tax rate 12.50% x 20%).
Get in Touch
For additional information about the attractive tax regime for individuals moving to Cyprus, or information regarding relocating there, please contact: advice.cyprus@dixcart.com.
Property has recorded double digit percentage growth in various sectors listed by numerous real estate service companies in recent years and the expectation is that this will continue – with an increased demand and reduced supply than previously seen.
What is an interesting misconception is that property prices are driven predominantly by the Golden Visa program – in actual fact, the Portuguese Golden Visa accounts for an insignificant portion of property purchases, when considered in comparison to total property purchases in Portugal.
This reflects that there are various factors in Portugal influencing properties prices, including: the fact that Portugal is the new acclaimed California, the new European Silicon Valley, it is ranked one of the best places to live and work in the world, it is an attraction magnet for digital nomads, as well as offering a 10-year tax holiday for the affluent, and there is more.
Property has always been a favourable investment class for many – and that is no different now. This raises the importance of understanding the related tax consequences of holding property in Portugal.
Dixcart have summarised below some of the tax implications applicable in Portugal.
Taxation Implications to Consider
What are the Tax Consequences for My Rental Income?
Rental income, for individuals is taxed at a flat rate of 28% – for both resident and non-resident Portuguese holders of property.
Qualifying expenses may be used to reduce the taxable income due – provided it forms part of the income producing activity.
Corporate tax rates for rental income depend on residency status: non-resident entities may be subject to 21% tax, whereas local Portuguese companies will be subject to tax at rates between 19% to 21% in mainland Portugal and 11.9% to 14.7% for properties located in the autonomous region of Madeira.
When is Stamp Duty Applicable?
Stamp duty is applicable on a variety of transactions in Portugal – this may occur when a property is inherited or when a property is purchased. Please refer below for more details.
What Inheritance Tax Implications Exist for Property (or is it Stamp Duty that Applies)?
Although inheritance tax is not applicable in Portugal, stamp duty does apply.
For the purposes of stamp duty, inheritance or gifts may fall into one of two categories – those which are exempt, and those taxed at a flat rate of 10%. Inheritances by close relatives, such as parents, children and spouses, are exempt from stamp duty. All other inheritances and gifts are taxed at a flat stamp duty rate of 10%.
Stamp duty is payable for the respective property, even if the recipient does not live in Portugal.
If you are a UK domicile, your Portugal property will form part of your UK estate for UK inheritance tax purposes.
Stamp Duty on the Purchase of a Property
Stamp duty on the purchase of a property is charged at a rate of 0.8% on the higher of the purchase price or VPT (the rateable value, attributed by the tax authorities). The VPT in most cases is much lower than the actual purchase price of the property.
The purchaser must pay this duty, prior to signing the final deed, and proof of payment will need to be provided to the notary.
VAT may be applicable on the purchase of new builds, in particular situations.
Property Transfer Tax
Property transfer tax, namely IMT (Imposto Municipal sobre Transmissões Onerosas de Imóveis), is applicable each time ownership is transferred. The tax is required to be paid by the purchaser prior to the final deed of sale being signed (as the original copy of proof of payment needs to be shown to the notary at the time of the property exchange).
The tax paid, is calculated on the higher of the purchase price or the VPT.
The property transfer tax rate is largely dependent on the ultimate use of the property and whether it is your first or second home, with the rates varying between 0% and 6%.
Companies, which have as their principal activity the purchase and sale of properties, enjoy an exemption from property transfer tax, if they can prove that they have sold other properties in the previous 2 years.
Annual Municipal Property Tax (IMI)
Annual municipal property tax, or IMI (Imposto Municipal sobre Imóveis), is payable by the person who is the property owner as at 31 December of the previous year, and is based on the VPT. The rate applied ranges from 0.3% to 0.8%, and is dependent on whether the property type is classified as urban or rural (classified by the Portuguese tax authorities and based on the location of the property). Note that any investor or company located in a blacklisted tax jurisdiction, in accordance with the Portuguese tax authority, will be subject to a flat rate of 7.5% IMI.
An additional annual municipal property tax, namely AIMI (Adicional ao IMI), is chargeable for any VPT value exceeding €600,000, for all residential properties and construction plots. The rate will vary between 0.4% and 1.5% depending on if you are taxed as a single person, or as couple, or as a company.
Please note that AIMI is not only considered for a single property but is taken into account per owner. If more than one property is therefore held, the cumulative VPT needs to be considered. If the cumulative VPT value for all properties held by a single owner exceeds €600,000, AIMI will be applicable on the value of the properties held, exceeding this threshold.
If the property is being used to promote an activity, such as extending local, affordable accommodation, there will be no AIMI.
What Tax Consequences are Applicable Upon the Sale of a Property?
Capital gains tax is applicable on the sale of a property, unless purchased before 1989.
The tax consequences vary dependent on whether you are resident or non-resident. In addition, the use of the property and the way that the proceeds from the sale are utilised are paramount, as this may have a significant impact on the related tax consequences applicable.
The tax is calculated on the difference between the selling price and the acquisition value (adjusted for inflation rates, net of documented costs incurred when the property was acquired, coupled with any capital improvements within the last 12 preceding years of the sale).
As a Portuguese tax resident, 50% of the gain is liable to tax. If the property was held for a period of two years or more, inflation relief may also be applicable. Capital gains, on your property, are added to your other annual income and are taxed at marginal tax rates of up to 48%.
It is worth noting that gains resulting from the sale of a primary residence are exempt for residents, if you reinvest all of the proceeds (net of any mortgage on the property), in another main home in Portugal or the EU/EEA, before the property is sold (a window of up to 24 months), or within 36 months of the disposal of the property, provided you live in the new property, within 6 months of the purchase.
Since 1st January 2023, capital gains tax for a non-resident, applies to 50% of the gain. The actual rate of tax will depend on the amount of other income earned across the world, by the non-resident.
Rates of capital gains tax are progressive, with the maximum rate being 48%.
The capital gains tax rate for non-residents companies is either 21% or 14.7%, depending on where the property is located.
Other Considerations
However, the tax consequences in Portugal are not the only considerations to take into account. The specifics of the relevant double taxation treaty needs to be examined, as well as the local laws and regulations applicable in the country of tax residence.
A typical example of this for a UK resident, is the fact that UK tax residents also pay tax on the gain from the Portuguese property in the UK, however, under the double taxation treaty, any tax paid in Portugal may be credited against the tax due in the UK.
Is there a Preferred Structure to Hold Property in Portugal?
A topical query – what is the most preferred and tax efficient structure to hold property in Portugal?
The answer may vary depending on the objectives and circumstances of each individual investor, as well as the proposed usage of such properties. It is however worth noting, that for a non-tax resident investor wishing to invest in property to earn rental income, holding such a structure through a Portuguese (resident) company may be beneficial, with tax rates varying between 17% to 21% for properties located on the Portuguese mainland and 11.9% to 14.7% for properties located in the autonomous region of Madeira, in comparison to the flat rate of 21% for non-resident entities.
For residents, holding a primary residence in their personal capacity, may be more beneficial from a capital gain point of view. Thus, each situation needs to be considered on a case-by-case basis.
Other considerations, however, need to be taken into account, such as the operational costs for running a company and ensuring appropriate substance exists. The cost of holding a property through a corporate structure may thus not exceed the benefit in all circumstances.
Alternative qualitative benefits may include the fact that corporate structures provide an extra layer of asset protection, which may be considered invaluable for many individuals located in jurisdictions exposed to considerable financial and other types of risk.
Summary of Property Tax Consequences
To summarise the tax and costs applicable for purchasers, owners, sellers and others, as discussed above, please refer below:
– IMI (Annual Municipal Tax) – AIMI (in addition to IMI) – Running costs (such as water and electricity)
Seller:
Others:
– Capital gains – Commission to real estate agency
Inheritance tax
The related tax rates may be summarised as follows:
Individuals
Residents
Non-Residents
Capital Gains Tax
– Primary residence may be subject to exemption – Second property will be taxed at 50% of the gain at progressive tax rates.
50% of the gain will be taxed at progressive tax rates.
Rental Income
– Lower of 28%; or – Marginal tax rate.
28%
Companies
Resident
Non-Resident
Capital Gains Tax
28%
Portugal: 21% Madeira: 14.7% Azores: 14.7%
Rental Income
Respective company tax rates: – Portugal: 17% to 21% – Madeira: 11.9% to 14.7% – Azores: 14.7%
Portugal: 21% Madeira: 14.7% Azores: 14.7%
Why is it Important to Engage with Dixcart?
It is not just the Portuguese tax considerations on properties, largely outlined above, but also the impact from where you may be tax resident and/or domiciled, that need to be considered. Although property is typically taxed at source, double taxation treaties and double tax relief need to be considered.
A typical example is the fact that UK residents will also pay tax in the UK and this will be calculated based on UK property tax rules, which may be different to those in Portugal. They are likely to be able to offset the Portuguese tax actually paid against the UK liability to avoid double taxation, but if the UK tax is higher, further tax will be due in the UK. Dixcart will be able to assist in this regard and to help make sure you are aware of your obligations and filing requirements.
How else may Dixcart Assist?
Dixcart Portugal have a team of experienced professionals who may assist with various aspects regarding your property; efficient tax planning, legal support (for the sale or purchase of a property), accounting and tax support and the incorporation and maintenance of companies.
Further to this, if you would like a deemed tax calculation to be performed, you may reach out to our offices in Portugal and/or Madeira for this information: advice.portugal@dixcart.com
Dixcart have helped many with this service and look forward to assisting you with your next property advice and/or transaction.
Cyprus offers various options for non-EU nationals to acquire residence. Each of these residence routes offer the additional advantage of leading to Cyprus citizenship, as long as the relevant criteria are met.
The different routes are:
Permanent Residence Permit through investment
Temporary Residence Permit through the establishment of a Foreign Interest Company
Temporary Residence Permit through the establishment of a Small and Medium Sized Innovative Enterprise (“Start-up Visa”)
The Cyprus pink slip. You must renew the pink slip annually. Under this permit, a person is allowed to live in Cyprus as a visitor (without the right to work). Also, his family members, spouse, and children (under 18 years old) can get the pink slip as dependants. The whole family applies at the same time; each family member files a separate application form and gets his temporary residence card.
The Category F permanent residence permit is available to individuals with an annual income of about EUR 15,000 for a family of two.
Category F is popular with pensioners and retirees. Both the investor visa and the Category F permit are permanent.
Digital Nomad visa: non-EU nationals who are self-employed, salaried, or working on a freelance basis can apply for the right to live and work from Cyprus remotely.
Applicants must work remotely using information technology and communicate remotely with clients and employers outside Cyprus.
A Digital Nomad has the right to stay in Cyprus for a period of up to one year, with the right to renew for another two years. During the stay in Cyprus the spouse or partner and any minor family members, cannot provide independent work or engage in any kind of employment activity in the country. If they reside in Cyprus for over 183 days in the same tax year, then they are considered to be tax residents of Cyprus.Each digital nomad must have; a salary of at least €3,500 per month, medical cover and a clean criminal record from their country of residence.
Currently the cap of the total amount of allowed applications has been reached and therefore this programme is currently unavailable.
We will elaborate here below the most popular options of the above mentioned routes.
PERMANENT RESIDENCE PERMIT
Cyprus has been a member of the European Union since 2004 and in order to attract additional foreign investment the Cyprus government introduced the Permanent Residence Permit scheme. Through this programme, non-EU nationals can guarantee their residence in the EU.
Requirements
The requirements for the Cyprus Residence Permit scheme are:
Make an investment of at least €300,000, in one of the following investment categories:
A. Purchase residential real estate (house/apartment) by a Land Development company in Cyprus, which should relate to a first sale of at least €300,000 (excluding VAT) OR;
B. Investment in real estate (excluding houses/apartments): Purchase other types of real estate, such as offices, shops, hotels, or related estate developments of a combination of these, with a total value of €300,000 (excluding VAT). Re-sale properties are acceptable. OR;
C. Investment of at least €300,000 in the share capital of a Cyprus company, which is based and operates in Cyprus, has substance in Cyprus, and employs at least 5 people in Cyprus. OR;
D. Investment of at least €300,000 in units of a Cyprus Investment Organisation of Collective Investments (type AIF, AIFLNP, RAIF).
Additional requirements:
Provide evidence of a secure annual income of at least €50,000. This required annual income increases by €15,000 for the spouse and €10,000 for every minor child. This income can come from; wages for work, pensions, stock dividends, interest on deposits, or rent. Income verification must be the individual’s relevant tax return declaration, from the country in which he/she declares tax residence. In the situation where the applicant wishes to invest as per investment option A, the income of the spouse of the applicant may also be taken into consideration. In calculating the applicant’s total income where he or she chooses to invest as per the options B, C or D, his/her total income or part of it may also arise from sources originating from activities within the Republic of Cyprus, provided that it is taxable in the Republic of Cyprus. In such cases, the income of the spouse of the applicant may also be taken into consideration.
Other Criteria
The applicant and their spouse must certify that they do not intend to be employed in the Republic of Cyprus except for their employment, as Directors in a company, in which they have chosen to invest within the framework of this policy.
In cases where the investment does not concern a company’s share capital, the applicant and/or their spouse may be shareholders in companies registered in Cyprus and the income from dividends in such companies shall not be considered as an obstacle for the purposes of obtaining the Immigration Permit. They may also hold the position of Director in such companies without pay.
Holders of the residence permit must visit Cyprus once every two years.
A clean criminal record, issued by the authorities of the country of existing residence & country of origin (if different), needs to be provided upon submission of the application.
Family Members
Residence permits can also be issued to the investors’ spouse and all financially dependent children.
The Option of Cyprus Citizenship
If the holder of a Permanent Residence Permit resides in Cyprus, this may make them eligible for Cyprus citizenship by naturalisation.
TEMPORARY RESIDENCE PERMIT VIA THE ESTABLISHMENT OF A FOREIGN INTEREST COMPANY
Key Features of a Cyprus Foreign Investment Company
A Cyprus Foreign Investment Company (FIC) is an international company which can employ non-EU nationals in Cyprus. Such a company can obtain work permits for relevant employees and residence permits for their family members.
Main Criteria
The main criteria for a Cyprus FIC are:
The third country shareholder(s) must own more than 50% of the total share capital of the company.
The third country shareholder(s) must contribute at least €200.000 to the share capital of the company. This investment can be used, at a later date, to fund future expenses incurred by the company when it is established in Cyprus.
Main Advantages
A key advantage is that after residing for seven years in Cyprus within any ten calendar year period, third country nationals can apply for Cyprus citizenship.
In the shorter term:
FICs can employ third country nationals, who can apply for appropriate residence and work permits, each of which will be valid for up to two years and are renewable.
Employees can exercise the right for their families to join them in Cyprus.
The corporate tax in Cyprus is at a competitive level of 12.5%.
A Cyprus FIC can also apply for the Notional Interest Deduction Regime, which reduces corporate taxation, by treating new equity in the same way as debt. Please contact Dixcart for more information: advice.cyprus@dixcart.com
Cyprus has Double Tax Agreements with almost 60 countries.
Dividend income is exempt from corporate and individual taxation.
Dividend distribution to shareholder(s), is exempt from withholding tax.
TEMPORARY RESIDENCE PERMIT VIA THE ESTABLISHMENT OF A SMALL AND MEDIUM SIZED INNOVATIVE ENTERPRISE (START-UP VISA)
The Cyprus ‘Start-up Visa’
The Cyprus Start-up Visa Scheme allows entrepreneurs (individuals or in a team), from third countries (outside the EU and outside the EEA), to enter, reside and work in Cyprus in order to establish, operate, and develop a start-up business.
Who Can Benefit from the Scheme?
Individuals
Non-EU country nationals who are the founders or owners of an enterprise that meets the following requirements:
the enterprise must beinnovative– research and development costs must represent at least 10% of its operating costs, in at least one of the three years preceding the submission of the application, as certified by an external auditor. In the case of a new enterprise, without any financial history, the evaluation will be based on a Business Plan that must be submitted to the Ministry of Finance.
the Business Plan must provide that the enterprise’s head office and tax domicile will be established in Cyprus.
Teams
Team consisting of non-EU nationals:
Founders that consist of a maximum of five individuals, or at least one founder plus other senior executives, up to a maximum of five individuals. The senior management must be to C-suite level employees (managers).
The team must own more than 50% of the company shares.
The founder must have access to a minimum €10,000. Where there are more than two founders, the total capital must be a minimum €20,000.
At least one of the team members holds an undergraduate or equivalent professional qualification.
The requirements mentioned above, relating to individuals and the enterprise criteria, also apply to team applications.
What are the Benefits of the Start-up Visa Scheme?
Individuals and team members, approved under the Start-up Visa Scheme, will benefit from the right to undertake economic activity and to reside in Cyprus for one year,with the option of renewing this for at least another year.
They have the right to self-employment and/or the right to paid employment in the company registered under the Start-up Scheme in Cyprus, with the prospect of permanent residence in Cyprus, as long as the business ‘succeeds’. Additional family members can move to Cyprus and a specified number of individuals from non-EU countries, can be employed, without prior approval from the Department of Labour, again assuming the success of the business. Success or failure of the business, will be assessed at the end of the second year of trading.
Amendments to the Income Tax Law mean that there are special tax incentives for ‘natural persons’ who are investing in innovative companies.
The type of investment subject to the tax reduction include: the capital investment, investment in debt instruments, investment in loans, follow-on investments. The tax reduction can be up to a maximum 50% of the investor’s taxable income in the year that the investment takes place. The amount of the tax reduction cannot be greater than €150,000 per year. It is possible for the tax reduction to be carried forward and enjoyed anytime during the five years following the investment.
Additional Information
If you require any further information, please contact Katrien de Poorter, in the Dixcart office in Cyprus: advice.cyprus@dixcart.com.
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