2025 UK Tax Changes for Non-Doms: Do’s and Don’ts

Significant changes were introduced to the UK’s tax rules for non-domiciled individuals from 6 April 2025. The remittance basis for non-UK domiciled individuals has been replaced with a residency-based system. Longer-term UK residents will be taxed on their worldwide income and gains as they arise. These changes mean that anyone affected needs to take a fresh look at their financial affairs. Good planning, keeping clear records, and getting the right advice will be important to avoid unexpected tax liabilities and to make the most of any reliefs still available.

Here are the essential Do’s and Don’ts for non-doms to help navigate the transition:

Do’s

1. Review Worldwide Income and Gains

  • From 6 April 2025, all longer term (over 4 years) UK tax residents must report and pay UK tax on worldwide income and gains as they arise, regardless of remittance.
  • Subject to appropriate advice you may wish to consider investing for long term capital growth or other financial strategies which defer the realisation of income.

2. Utilise the Temporary Repatriation Facility (TRF)

  • Review previous UK tax returns and consider if appropriate to claim the remittance basis for 24/25 in order to benefit from the transitional provisions.
  • Consider remitting pre-6 April 2025 foreign income and gains under the TRF, available for the 2025/26 and 2026/27 tax years, to benefit from a reduced tax rate. ​
  • Review remittances under the TRF to ascertain the most efficient for taxed or untaxed income and gains taxed outside of the UK.

3. Maintain Detailed Records

  • Keep comprehensive documentation of all foreign income, gains, and remittances, including dates, amounts, sources, and related bank statements and foreign taxes paid.

4. Rebase Foreign Assets if Eligible

  • If you have claimed the remittance basis and were neither UK domiciled nor deemed domiciled by 5 April 2025, you may elect to rebase the value of foreign capital assets held personally on 5 April 2019 to their value on that date. Ensure you have records and valuations (where possible) of such assets. ​

5. Review Offshore Trusts and Structures

  • Review any trusts you are either settlor or beneficiary of.
  • Assess the implications of the new rules on offshore trusts, as protections from UK taxation on foreign income and gains arising within such trusts will be removed for most individuals. ​
  • Review any closely held foreign companies you are a shareholder of.

6. Monitor Residency Status

  • Keep accurate records of your days spent in and out of the UK to determine your residency status under the Statutory Residence Test.​
  • Consider if you are tax resident in another jurisdiction also and whether any applicable DTA may apply.

7. Seek Professional Advice Before Transactions

  • Consult with tax professionals before making significant financial decisions, such as selling foreign assets or making large transactions, to understand the UK tax implications.​

🚫 Don’ts

1. Don’t Assume Previous Non-Dom Benefits Still Apply

  • The remittance basis has been abolished from 6 April 2025; relying on previous non-dom advantages could lead to unexpected tax liabilities. ​

2. Don’t Overlook Taxation of Trust Distributions

  • Distributions or benefits from offshore trusts may now trigger UK tax charges; ensure you understand the new tax treatment before receiving such distributions. ​

3. Don’t Delay Using the TRF for Pre-2025 Foreign Income and Gains

  • The TRF offers a limited window to remit pre-6 April 2025 foreign income and gains at a reduced tax rate; This applies for two years at 12% and then one year at 15% delaying beyond this period may result in higher tax charges. ​
  • Don’t assume claiming the TRF will be the most efficient form of remittance, particularly for taxed gains.
  • Don’t assume you will get any or full credit for foreign taxes already suffered.

4. Don’t Neglect Mixed Funds

  • Bringing funds into the UK from accounts containing both clean capital and income/gains without proper tracing can lead to unintended tax consequences.​

5. Don’t Ignore Inheritance Tax (IHT) Changes

  • The UK is moving to a residence-based IHT system; long-term UK residents may be subject to IHT on worldwide assets. Keep detailed records of any gifts or transfers you make, especially if they involve offshore assets.

6. Don’t Make Assumptions About Overseas Workday Relief (OWR)

  • OWR will continue but with changes; ensure you understand the new eligibility criteria and conditions. ​

7. Don’t Undertake Complex Transactions Without Advice

  • Transactions involving offshore trusts, closely held companies, foreign asset sales, company reconstructions, or significant remittances can have complex tax implications; always seek professional guidance.

7. Don’t Undertake Complex Transactions Without Advice

  • Just because a transaction or a particular source of income is exempted from tax outside of the UK do not assume that this will be the case in the UK.

Contact Us

At Dixcart UK, we are here to help you manage the upcoming changes to the non-dom regime with clear, tailored advice.

Get in touch with us or connect with one of our offices across the Dixcart Group to find out how we can support you during this transition.

The EU Blue Card in Cyprus and its Benefits

The “EU Blue Card” refers to a newly introduced residence permit allowing highly skilled, non-EU nationals to work and live in Cyprus, especially in sectors facing shortage of highly qualified personnel. The Blue Card scheme simplifies the process for qualified individuals to work and reside in the European Union and is valid in all European countries excluding Denmark and Ireland.

The EU Blue Card scheme will enhance the framework for attracting highly qualified professionals, thus enabling Cyprus to further establish itself as a hub for innovation and technology. Unlimited Blue Card positions are available in the Information and Communication Technologies (ICT) sector, pharmaceutical research and maritime industry (excluding ship captains and crew).

Who Qualifies for an EU Blue Card?

In order for a non-EU national to apply for an EU Blue Card, the below must be met:

  • A valid employment contract or binding job offer of at least six months in the Republic of Cyprus for a highly skilled employment.
  • Higher education qualifications following studies of at least three years, while professionals in the ICT sector must have a minimum of three years’ professional experience within seven years preceding the EU Blue Card application.
  • The Cyprus authorities have set a minimum annual gross salary of €43,632. In practice, the law provides that the gross annual salary should not be lower than the set national minimum wage and should be at least equal to the average gross annual salary of Cyprus.
  • Valid health insurance coverage.

Application Procedure & Period of Validity

The application procedure is quite simple. The Department of Labour must verify the employment contract and qualifications and then the Blue Card application and required documents must be submitted to the Civil Migration Department.

If approved by the authorities, the Blue Card is issued with a minimum validity of 24 months, with the possibility to apply for a renewal within three months before its expiry as long as certain conditions are met.

EU Blue Card: Key Benefits

  • Blue Card holders are granted the right to work in high-demand professions with competitive salaries comparable to those of EU nationals.
  • Family members of non-EU nationals have the right to apply for residence in the Republic of Cyprus through the family reunification process and are guaranteed access to any kind of employment, including self-employment, in accordance with Cypriot legislation.
  • Blue Card holders enjoy the same working conditions, educational opportunities, social security benefits, and access to services as the host country’s citizens.
  • Cardholders can travel visa-free across EU member states and relocate to another EU country for work after 12 months of residence in the issuing country.
  • Blue Card holders can apply for long-term residence after 33 months and for citizenship after five years, provided they meet certain conditions such as language proficiency and pension contributions.

These amendments will come into force upon publication in the Official Gazette of Cyprus and once they have been officially adopted, it is expected that the Migration Department will issue further clarifications and guidance notes.

How Can Dixcart Help You?

Dixcart has been assisting its clients with international structing and company incorporation and management for over 50 years. We offer a wealth of in-depth local knowledge and our team at Dixcart Management (Cyprus) Limited have become experts in our field.

We will help you gather and collate all the required documents and assist in ensuring that all required criteria are met dealing with the governing bodies on your behalf to ensure that everything is fully compliant with local and international requirements and regulations.

If you would like to know more about the benefits of applying for an EU Blue Card or if you have any questions about how we can help you please contact us at the Dixcart office in Cyprus for further information: advice.cyprus@dixcart.com

Why Cyprus is the Perfect Retirement Destination and the Tax Benefits

Introduction

If you are considering retiring abroad, there are numerous factors to take into account, ranging from affordability and quality of life to visa requirements and taxation policies.

With over 320 days of sunshine a year, free healthcare, and a variety of visa options with attractive tax benefits, Cyprus has become a top choice for retirees seeking to make the most of their retirement.      

Immigration Options

As a member of the European Union (EU), Cyprus offers the right to live and work in the country for all EU and European Economic Area (EEA) citizens, making relocation straightforward for those from these regions.

For non-EU and non-EEA citizens, commonly referred to as third-country nationals, there are several pathways to residency. The two most popular options are:

  1. Establishing a Foreign Interest Company (FIC)
  2. Residency by Investment

Please find our detailed article on these routes here.

Other residency pathways are available, though they tend to be less commonly used and may involve a more extended application process. If you are considering moving to Cyprus and feel that neither of the above options suit your circumstances, please feel free to contact our team. We would be happy to explore alternative solutions tailored to your situation.

Tax Benefits

Tax on your foreign pension

Once you become a tax resident in Cyprus, your foreign pension income becomes subject to Cyprus taxation on a worldwide basis (provided it is not an excluded pension, such as a UK Government service pensions).

You have the flexibility to choose between two tax options each year:

Option 1 – 5% tax

This straightforward option taxes all your pension income at a flat rate of 5%, after applying a tax-free allowance of €3,420.

Option 2 – The standard income tax rates

Under this option, your pension income is combined with your other annual income and taxed according to the standard income tax rates, as outlined below:

Chargeable income for the tax year (EUR)Tax rate (%)
0 – 19,5000%
19,501 – 28,00020%
28,001 – 36,30025%
36,301 – 60,00030%
60,001 and above35%

Each individual should assess their situation annually and select the most suitable option, declaring their choice on their tax return.

Pension Lump Sums

Pension commencement lump sums are not taxable in Cyprus, even if received whilst resident in Cyprus. This exemption falls under the domestic ‘exempt income’ rules.

Other Tax Benefits

Non-Domicile Regime:

In addition to the previously mentioned benefits, you may also qualify for the Cyprus Non-Dom regime. This tax regime lasts for 17 years with no buy-in cost. If eligible, you can take advantage of the following benefits:

  • 0% income tax on dividends, capital gains, and most types of interest
  • 50% exemption on salaried income, provided you meet the criteria

For those with investment income or those receiving dividends from a family business, this regime allows you to receive these amounts free from personal income tax.

For more detailed information about the Non-Dom regime, please refer to our article here.

Inheritance Tax

It is important to note that there is no inheritance tax or gift tax in Cyprus, a benefit available to both Non-Doms and ordinary residents.

Other Notable Advantages

While the tax advantages are significant, they are rarely the sole reason individuals move to Cyprus. Individuals and their families relocate to the island for a variety of reasons, including:

  • Cyprus has a very high standard of living and is considered one of the safest countries in Europe.
  • The island offers excellent free healthcare, ranked among the highest quality in the world, surpassing countries like Canada and the UK.
  • Cyprus is well connected with two international airports providing links to many European destinations and daily flights to hubs such as Dubai, Qatar, and Abu Dhabi.
  • The local culture is welcoming and friendly, with a strong emphasis on family-oriented lifestyles.
  • Of course, the weather is a significant draw. Cyprus enjoys over 320 days of sunshine per year, with minimal rainfall compared to the rest of the EU. While summers can be very hot, the island experiences all four seasons, and it cools off nicely in the winter. There is even a ski resort on the highest mountain.

How Can Dixcart Help?

At Dixcart, we leverage over 50 years of experience to assist individuals worldwide in finding tailored solutions and executing their plans. For immigration clients, we provide comprehensive support, from gathering required documents for visa/residency permits to guiding you through tax structuring and even accompanying you to immigration offices.

If you are considering moving to Cyprus, reach out to us at advice.cyprus@dixcart.com to see how we can assist you.

Moving to Cyprus and the Non-Domicile Regime

Introduction

With over 20% of the population being made up of expats it is clear that Cyprus has become a hotspot for those looking to relocate. There are several benefits drawing people to Cyprus, ranging from a high standard of living and excellent healthcare system to the wide array of taxation benefits and visa options. The 320 sunny days a year also helps convince some.

In this article we will briefly summarise the routes to residency through the two most popular immigration options, as well as outline the key benefits of the Cyprus Non-Domicile (Non-Dom) Regime.

Immigration Options

 EU and EEA citizens

As a member of the European Union (EU), Cyprus offers the right to live and work in the country for all EU and European Economic Area (EEA) citizens, making relocation straightforward for those from these regions.

Non-EU and Non-EEA citizens

For non-EU and non-EEA citizens, commonly referred to as third-country nationals, there are several pathways to residency. The two most popular options are:

  1. Establishing a Foreign Interest Company (FIC)

Rights: This route gives you (and your family members) the right to live and work in Cyprus.

Investment requirement: An investment of €200,000 of paid-up capital that can be later used to fund the expenses of the company or used for investments to generate income.

See our full detailed article here if this route to residency interests you.

  1. Residency by Investment

Rights: This route gives you the right to live in Cyprus but not the right to work. This means you may not take up any employment in the republic but does not limit you from being the owner and a director on a Cyprus resident company, thus receiving dividends, or working for an overseas entity.

Investment requirement: A local investment of €300,000 is required. This is commonly done through the purchase of a residential property to live in.

See our full detailed article here if this route to residency interests you. Please note there have been some recent changes to the permanent residency regime, we have done a detailed article on these changes here.

  1. Other residency options

A number of other options are available, though they tend to be less commonly used and may involve a more extended application process. If you are considering moving to Cyprus and feel that neither of the above options suits your circumstances, please feel free to contact our team. We would be happy to explore alternative solutions tailored to your situation.

Cyprus Non-Domicile Regime

When you become a tax resident in Cyprus you may qualify for the Cyprus Non-Dom regime, provided you or your father were not born in Cyprus. This tax regime lasts for 17 years with no buy-in cost.

If eligible and you complete your application, you can take advantage of the following benefits:

  • 0% tax on dividends, capital gains, and most types of interest
  • 50% income tax exemption on salaried income, provided you meet the criteria

For those with investment income or receiving dividends from an overseas business, this regime allows you to receive these amounts free from tax.

For more detailed information about the Non-Dom regime, please refer to our full article here.

How Can Dixcart Help

At Dixcart, we leverage over 50 years of experience to assist individuals worldwide in finding tailored solutions and executing their plans. For immigration clients, we provide comprehensive support, from gathering required documents for visa/residency permits to guiding you through tax structuring and even accompanying you to immigration offices.

If you are considering moving to Cyprus, reach out to us at advice.cyprus@dixcart.com to see how we can assist you.

Portuguese Golden Visa 2025 Processing Updates

The Portuguese Immigration and Borders Service (AIMA) recently held a meeting (January) with legal representatives to discuss key updates and processing changes for the Portuguese Golden Visa programme in 2025.

The key changes can be summarised as follows:

  • Citizenship Residency Period: The five-year residency period for citizenship begins on the date of the initial application fee payment (allowing elapsed time since application not to be wasted – as it counts toward the five-year residency requirement for citizenship).
  • Digital Transition: AIMA is moving to a fully digital system to streamline processing. Expect a transition period for pending cases (applications awaiting their initial biometric appointments will be prioritised).
  • Document Validity: All documents will need to be re-submitted online (this includes personal and investment-related documentation). Their validity will be assessed based on the resubmission date.
  • Language Flexibility: Documents in English, Spanish, or French no longer require translation.
  • Final Fees: Final fees are to be paid at the biometric appointment. Reimbursement is available for rejected applications.

Other relevant updates include the following:

  • AIMA aims to streamline application processing and improve efficiency by transitioning towards greater reliance on digital platforms. To this end, they are prioritising applications awaiting their initial biometric appointments and focusing on addressing abandoned applications.
  • Biometric appointments will be scheduled from 15 January 2025, in chronological order of document uploads. Appointments can be scheduled between 30 to 90 days in advance.
  • Following successful biometrics and a thorough review, AIMA will proceed with the issuance of Golden Visa cards. Applicants will be notified if any issues are identified during the process and required to make corrections.
  • Existing cards remain valid until June 2025. Renewals will continue to be processed in person at AIMA offices. A dedicated platform for booking renewal appointments will be made available in the coming months. Dixcart is actively requesting in-person biometrics appointments for renewal applications.
  • Card validity varies based on the investment type: two years for fund-based clients and three years for property-based clients. Government fees are subject to potential changes.

Disclaimer: This information is provided for general guidance for discussion purposes and should not be considered advice.

Reach out to Dixcart Portugal (advice.portugal@dixcart.com) for more information.

What are the Tax Consequences of the NHR Regimes?

Taxpayers who are NHR (Non-Habitual Residents) or IFICI (Incentive for Scientific Research and Innovation) eligible, benefit from a package of respective tax advantages, for a period of 10 consecutive calendar years (with the option of utilising the marginal rates, if lower), from the effective date of Portuguese tax residency.

Summary of Tax Consequences Differentiating between the Previous and New NHR (IFICI/NHR2.0) Regime

Previous NHR Regime (Grandfathered – respective tax residents continue to benefit from old rules)New NHR Regime (“NHR 2.0”), IFICI (Effective 1 January 2024)
Who does this apply to?Those who became tax resident before 31 December 2023, or those, under the transitional rules, became tax resident before 31 December 2024.Those who become tax resident on or after 1 January 2024 onwards and comply with the respective criteria – see link.
Employees or contractors of a Portuguese based entity20% taxation for high value-added activities.20% taxation for work for certain eligible activities.
Employees or contractors working for a foreign based company (exception for exempt salary income)20% taxation for high value-added activities if the income is not taxed in the source state.Not subject to tax if a high value-added activity or otherwise subject to progressive taxation up to 48% plus surtaxes.
HNWI deriving only passive related income (foreign)Only certain foreign passive income may be exempt. Portfolio gains generally taxed at 28%. Blacklisted tax jurisdictions (35%).Not subject to tax, with exception from blacklisted tax jurisdictions (35%).
HNWI deriving only passive related income (local/Portugal)28% (unless marginal rates apply, if lower), or other exemptions.28% (unless marginal rates apply, if lower), or other exemptions.
Pensioners10% or exempt.Progressive taxation up to 48% plus surtaxes.
R&D work performed in Portugal20% taxation for high value-added activities. Other foreign passive income may be exempt.20% taxation for work for certain eligible activities. Exempt on foreign income from several categories of income.

I am part of the previous NHR – does this affect me?

As the previous NHR regime will be grandfathered (including those who become tax resident before 31 December 2024), there is no impact for individuals already enjoying NHR status. The regime will continue to exist until the 10-year NHR period is reached, from when each respective individual registered for NHR.

Contact Us

Dixcart Portugal provide a host of services to international clients. Reach out for more information (advice.portugal@dixcart.com).

Note that the above must not be considered as tax advice and is for discussion purposes only.

Portugal’s Revised Non-Habitual Residents (NHR) Regime: Process and Requirements Explained

Following the Government’s release of regulations in December 2024, Portugal has reintroduced a new Non-Habitual Residents Regime (NHR), known as “NHR 2.0” or IFICI (Incentive for Scientific Research and Innovation). The new regime is, effective from 1 January 2024 – a redesigned tax incentive scheme replacing the previous NHR.

The scheme, to summarise, is to allow those who choose Portugal as their base for establishing their business or exercising a respective professional activity in Portugal, to benefit from several tax advantages.

The key benefits, available for 10 calendar years from the time they become tax resident in Portugal, are summarised as follows:

  • 20% flat tax rate on qualifying Portuguese income.
  • Exclusion from tax for foreign-sourced business profits, employment, royalties, dividends, interest, rents, and capital gains.
  • Only foreign pensions and income from blacklisted jurisdictions remain taxable.

Requirements for the New NHR:

Those intending to benefit from the new NHR can do so provided they comply with the following set of requirements:

  1. Application Deadline: Applications must generally be submitted before 15 January of the following year after becoming tax resident in Portugal (Portugal’s tax years run in line with calendar years). A transitional period applies for those who became tax resident between 1 January and 31 December 2024, with a deadline of 15 March 2025.
  2. Prior Non-Residency: Individuals must generally not have been tax resident in Portugal in the five years preceding their application.
  3. Qualified Professions: To be eligible, individuals must be employed in at least one highly qualified profession, including:
    • Company Directors
    • Specialists in physical sciences, mathematics, engineering (excluding architects, urban planners, surveyors, and designers)
    • Industrial product or equipment designers
    • Doctors
    • University and higher education teachers
    • Specialists in information and communication technologies
  4. Qualification Criteria: Highly qualified professionals typically require:
  1. A minimum of a bachelor’s degree (equivalent to Level 6 on the European Qualifications Framework); and
  2. At least three years of relevant professional experience.
  1. Business Eligibility: to qualify for the Portuguese NHR under the business eligibility criteria, individuals must be employed by companies that meet specific requirements, namely:
    • Eligible businesses must operate within specific economic activity codes (CAE) as outlined in the Ministerial Order.
    • Companies must demonstrate that at least 50% of their turnover is derived from exports.
    • Belong to eligible sectors, including extractive industries, manufacturing, information and communication, R&D in physical and natural sciences, higher education, and human health activities.
  2. Application Process:
    • Specific forms must be submitted to the relevant authorities (which may include the tax authorities) for eligibility verification. This is something Dixcart Portugal may assist with.
  3. Application Documents: Required documents may include:
    • Copy of employment contract (or scientific grant)
    • Up-to-date company registration certificate
    • Proof of academic qualifications
    • Statement from the employer confirming compliance with the activity and eligibility requirements
  4. Annual Confirmation:
    • The Portuguese tax authorities will confirm the NHR 2.0 status annually by 31 March.
    • Taxpayers must maintain records demonstrating that they carried out the qualifying activity and generated the corresponding income during the applicable years and provide this evidence upon request to benefit from the respective tax advantages.
  5. Changes and Termination:
    • If there are changes to the original application details that affect the competent authority or the entity verifying the value-added activity, a new application must be filed.
    • In case of any changes to, or termination of, the qualifying activity, taxpayers are required to inform the relevant entities by 15 January of the following year.

What are the Tax Consequences for my Income Sources?

The tax rate and treatment will vary – please refer to our article on Tax Consequences of the Non-Habitual Residents Regime for more information.

Contact Us

Dixcart Portugal provide a host of services to international clients. Reach out for more information (advice.portugal@dixcart.com).

Note that the above must not be considered as tax advice and is for discussion purposes only.

Exciting Changes to the Cyprus Startup Visa Scheme and New Opportunities for Global Entrepreneurs

Introduction

At the end of 2024 a number of revisions to the existing Cyprus Startup Visa Scheme were approved. These changes make an already very attractive scheme more appealing and accessible.

Overview of the Scheme

The Cyprus Startup Visa Scheme allows talented entrepreneurs from non-EU and non-EEA countries, whether individuals or a team, to enter, reside and work in Cyprus while establishing, operating, or growing a high-potential Startup. The aim of the scheme is to create new job opportunities in Cyprus, promote innovation and research, grow the business ecosystem and consequently the overall economic development of the country.

For the purposes of the Scheme, Innovative Startups are defined as unlisted small enterprises registered within the last 5 years, with no profit distribution and have not been formed through a merger. The enterprise should develop or offer new products, services, or processes that create or disrupt markets. Such innovations are based on new technologies, should adapt existing technologies, and/or employ new business models.

Beneficiaries of the Scheme are categorised under either the ‘Individual Startup visa scheme’ or under the ‘Team Startup visa scheme’.  A team is considered as “a maximum of 5 individuals consisting of non-EU country nationals”. The Team should consist solely of the founders of an innovative Startup or of at least one founder and other senior executives. In both the Individual and the Team Startup visa scheme at least 25% of the company’s shares should be owned by one or more member(s) of the applicant or team of applicants.

What has Changed?

The revisions to the Cyprus Startup Visa Scheme include:

  • An extension to the residence permit offered to successful applicants from 2 to 3 years, with a possibility of 2-year renewals, instead of the original renewal for 1 year;
  • A reduction to the required percentage of equity third country applicants must have in the Cypriot company from 50% to 25%. It is noted that a start-up group applying for this specific visa may consist of up to five founders (or one founder and additional executive members), and must have a minimum of €20,000 capital or €10,000 if the founders are less than two;
  • The ability to increase the number of third country nationals employed from 30% to 50% of the company’s entire staff, with the option of hiring additional foreign personnel if the start-up investment in Cyprus is equal to, or exceeds, €150,000;
  • The implementation of different evaluation criteria for start-ups that have sales revenues of at least €1,000,000, and whose research and development expenditure amounts to at least 10% of the total operating expenses for one of the past 3 years.

While the updated programme offers greater flexibility to foreign entrepreneurs and investors, it also establishes more distinct and objective conditions for the renewal of the start-up visa after the initial 3-year period. Specifically, start-ups wishing to renew their relevant visas will be required to demonstrate either a minimum increase of 15% in their revenues or investments of at least €150,000 during the period of their operation in Cyprus. Additionally, the companies applying for a renewal visa will be expected to have either created at least 3 new jobs in Cyprus, or participated in a local innovation support scheme, or launched at least one product or service.

Tax Benefits

With an ever-expanding double tax treaty network of approximately 70 countries across the globe, Cyprus offers a number of tax benefits to start-ups and foreign investors of such start-ups, such as:

  • A non-Cypriot individual relocating to Cyprus to set-up their startup is exempt from tax on dividends, capital gains and most types of interest income, though they will still be subject to income tax on any income earned as a salary from their employment in Cyprus.
  • Investors in innovative start-up companies (which have been certified as such by the Ministry of Finance in Cyprus) can enjoy up to 50% tax exemption on their annual taxable income in Cyprus.
  • Corporate tax on net profits of Cypriot companies is currently set at 12.5%. Technology companies producing Intellectual Property can apply for an 80% tax exemption, reducing the corporate tax rate to an effective 2.5%.
  • Capital gains arising from the disposal of the qualifying IP are fully exempt from tax. Any gains earned by the entrepreneur from the disposal of his/her shares in a Cypriot tax resident company are generally exempt from tax in Cyprus.
  • Cyprus tax resident companies may carry forward tax losses incurred during a tax year over the following 5 tax years to offset future taxable profits, allowing startups, which are commonly loss making in their early stages, to benefit in the future.
  • Upon the introduction of new equity, a Cyprus tax resident company is entitled to claim a notional interest deduction (NID) as a tax-deductible expense. The deduction is available on an annual basis and may reach up to 80% of the taxable profit generated from the new equity. Depending on the level of capitalisation, a startup company may reduce its effective tax rate to as low as 2.5%.
  • Profits from disposals of corporate ‘titles’ are tax exempted from corporate income tax. However, capital gains on immovable property situated in Cyprus (on non-quoted shares directly or indirectly holding such Cyprus-situated immovable property) are taxed.
  • Special defence contribution is imposed only on non-exempt dividend income, ‘passive’ interest income, and rental income earned by Cypriot tax resident companies and Cypriot permanent establishments of non-Cyprus tax resident companies.

How can Dixcart Cyprus Help?

With over 50 years of expertise in the industry, we bring a deep understanding of supporting individuals, families, and businesses. Our teams combine extensive knowledge of the local regulatory framework with the global reach, resources and expertise of our international group, ensuring we deliver tailored solutions that perfectly meet your needs.

At Dixcart, we recognise that every client is unique, and we pride ourselves on offering personalised services. By working closely with you, we gain an in-depth understanding of your specific requirements, enabling us to provide bespoke solutions, recommend the most suitable structures, and support you every step of the way.

Our comprehensive range of services include company incorporation, management and accounting services, company secretarial support, and even providing a fully serviced office for your Cypriot company.

If you are considering how Cyprus can play a role in managing your wealth or business needs, we would be delighted to discuss your options. Please do not hesitate to contact us at advice.cyprus@dixcart.com.

Malta’s Permanent Residence Programme: Key Changes Effective January 2025

What is the Malta Permanent Residence Programme (MPRP)?

The Malta Permanent Residence Programme (MPRP) was introduced in 2021, when it replaced the Malta Residence and Visa Programme (MRVP). The MPRP is designed to grant permanent residency to non-EU/EEA/Swiss nationals and their eligible family members. The programme aims to attract foreign investment while offering successful applicants the right to reside in Malta and access benefits such as visa-free travel within the Schengen Area.

As per Legal Notice 310 of 2024 published by the Maltese Government on 19 November 2024, the MPRP has undergone several key changes to the eligibility criteria and overall costs. MPRP. These amendments affect all MPRP applications from 1 January 2025.

What are the Key Changes?

The most significant changes are as follows:

  • New Financial Eligibility Criteria

Prior to the changes taking effect in January 2025, applicants were required to possess a minimum of €500,000 in assets, including at least €150,000 in financial investments. Under new provisions, applicants will have two options:

  1. showing that they have capital assets of a minimum €500,000, out of which a minimum of €150,000 must be financial assets; OR
  2. show they have capital assets of a minimum €650,000, of which €75,000 must be in the form of financial assets.
  • Age Limit for Dependant Children and New Fees for Dependants

Before the changes in the rules, a dependant child included in the application could be over 18 years old, unmarried, and primarily financially reliant on the main applicant. This applied to biological and adopted children of the main applicant or their spouse, provided they met the criteria set by the Residency Malta Agency. From 1 January 2025, the definition of a dependant child will change to include only those who are under 29 years old at the time of application. This new age limit does not apply to adult children certified by a recognised medical authority as having a disability.

A fee of €10,000 per dependant has been introduced, consisting of a combination of a €5,000 non-refundable administrative fee and a €5,000 financial contribution. There are no fees for dependants apply under the current version of the programme.

  • Qualifying Property Costs

The minimum thresholds for qualifying owned or rented property are set to increase.

Post-amendments, starting 1 January 2025, the minimum property purchase value will increase to €375,000 (previously, the minimum price was €300,000 for properties in Gozo or the South of Malta and €350,000 for properties in other areas) and the minimum annual rent for qualifying rented property will increase to €14,000 (before this change, the minimum annual rent was €10,000 for properties in Gozo or the South of Malta and €12,000 for properties in other regions).

Under the new provisions, the location of the property will not impact the financial contributions due by the applicant.

  • Main Applicant’s Financial Contribution

The contributions that applicants will have to pay have increased from €28,000 to €30,000 for applicants who choose a qualifying owned property, and from €58,000 to €60,000 for those who opt for a qualifying rented property. The contribution must be made within eight months of the issuance of the approval letter.

  • Administrative Fee

The administration fee for applications submitted after 1 January 2025, will increase to €50,000 (from €40,000 under the previous regime). This fee is non-refundable, with €15,000 payable within one month of application submission and the remaining €35,000 due within two months of receiving the letter of approval in principle. For dependants, a total fee of €10,000 will apply (an increase from €7,500). Of this, €5,000 is a non-refundable administration fee, which must be paid within two months of the letter of approval in principle. The remaining €5,000 is payable within eight months of the same letter. If a dependant is added after the certificate of residence is issued, the non-refundable portion must be paid when the application is submitted.

There will be no changes to the investment route which involves making a donation of €2,000 to a local philanthropic, cultural, scientific, artistic, sport or animal welfare NGO registered with the Commissioner of Voluntary Organisations.

How Dixcart Can Assist?

The Dixcart office in Malta has extensive experience in guiding clients through the application process of the MPRP and the various residence programmes available in Malta.

For further information, please contact Jonathan Vassallo at the Dixcart office in Malta: advice.malta@dixcart.com. Alternatively, feel free to reach out to your usual Dixcart contact.

2024 Overview: Key Articles and Insights from Dixcart Switzerland

Introduction

As we approach the end of 2024, we reflect on the key articles shared by our Switzerland office this year. Below are concise summaries of Dixcart Switzerland’s 2024 articles, offering practical guidance on Swiss residency, trusts, and business opportunities.

1. Swiss Regulation: 2023 Overview and What to Expect in 2024
Key regulatory updates for 2024 include VAT rate increases, a 15% minimum corporate tax for multinationals, and the removal of import duties to boost economic competitiveness. Reflections on 2023 cover the Swiss-UK financial treaty, updates to the Federal Act on Data Protection, corporate law reforms, and enhanced anti-money laundering measures.

2. Setting Up a Business in Switzerland
Comprehensive guidance on starting a business in Switzerland, including legal structures such as sole proprietorships, partnerships, and limited liability companies. Highlights include essential steps for registration, tax implications, and adherence to employment regulations.

3. Dixcart Gains Regulated Trustee Status in Switzerland – Understanding the Significance
Dixcart Trustees Switzerland (SA) attained regulated trustee status from FINMA, aligning with Swiss structural and business-conduct standards. Key advantages of Swiss trusts include confidentiality, tax efficiency, and enhanced wealth preservation opportunities.

4. The Role of a Swiss Trustee: Exploring How and Why They are Beneficial
Swiss Trustees play a pivotal role in estate planning, wealth management, and asset protection. Switzerland’s central location, leading banking infrastructure, and strong commitment to confidentiality make it an ideal jurisdiction for trustee services.

5. How to Become Swiss Resident by Working in Switzerland
Switzerland provides several routes to residency through work, including employment with a Swiss company, forming a business, or investing in one. EU/EFTA nationals benefit from easier processes, while non-EU/EFTA nationals have stricter requirements. Taxation differs by canton, and contributions through business activities often benefit local economies.

6. Introduction of Swiss Trusts
Swiss Trusts and Private Trust Companies (PTCs) offer secure asset protection, confidentiality, and succession planning options. Trusts under foreign laws are recognised in Switzerland, and taxation depends on the residency of the settlor and beneficiaries. FINMA-regulated Trustees uphold strict confidentiality and compliance standards.

7. Guide to Establishing and Managing a Swiss Company
Switzerland is an attractive location for businesses, offering low tax rates, political stability, and a prime European location. Incorporation typically takes three weeks, with options like SARL or SA structures. Flexible labour laws, VAT compliance, and favourable tax treatment for dividends and capital gains strengthen the benefits of operating in Switzerland.

Additional Information

For additional details on any of these topics or assistance with related services, please contact Christine Breitler at our Switzerland office: advice.switzerland@dixcart.com.