Is your Portuguese NHR coming to an end? Have you considered Cyprus?

Introduction

Here is the scenario; You have been making the most of Portugal’s fantastic tax regime for Non-Habitual Residents (NHRs) for the last 9 years. But you know that your NHR status will come to an end after the 10th year, and, if you stay in Portugal, you will have to pay tax at the standard Portuguese rates once it does end.

We understand that many of those coming to the end of their NHR status will have made Portugal their home and will be willing to remain tax resident in Portugal. However, others may decide that their tax exposure would be too great and so will be considering moving and becoming a tax resident somewhere else. But where?

The Dixcart Group have been advising clients on questions such as this for over 50 years. Being a global group we have experienced teams with expert local knowledge in a variety of jurisdictions working as one to help you with your decision.

In this article we explore why we believe a move to Cyprus could be exactly what you are looking for.

Why Cyprus?

Cyprus is an appealing European jurisdiction, located in the eastern Mediterranean Sea offering a warm climate and attractive beaches. Cyprus is the 3rd largest and 3rd most populated of the Mediterranean Islands and so offers a lot of choice for those considering relocating. There is a perfect balance of cosmopolitan living and rural villages to choose from. While Nicosia serves as the centrally located capital of the Republic of Cyprus, the growing financial hub resides in Limassol on the southern coast.

Strategically located at the crossroads of three continents, Cyprus is accessible from Europe, Asia and Africa. The official language is Greek, with English also being widely spoken. Cyprus also offers great public sector services such as a fantastic healthcare system and excellent schools.

Given the high standard of living and the palette of choice available on the island, together with the corporate and personal tax incentives for expatriates and high net worth individuals, relocating to Cyprus has long been the first choice for many expats looking for a place to settle.

How do I Become a Cyprus Tax Resident?

Individuals can move to Cyprus and become a Non-Domiciled Tax Resident, by spending at least 183 days in Cyprus without additional conditions. This Non-Domiciled Tax Residency status is applicable for 17 out of 20 years and comes with a wide array of benefits.

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 increasingly popular ‘60 Day Tax Residency Rule’ might be of interest.

To be eligible for the ‘60 Day Tax Residency Rule’ you’re required to meet the below criteria:

  • Reside in Cyprus for at least 60 days in a property which you own or rent.
  • Operate/run a business in Cyprus and/or be employed in Cyprus and/or act as a director of a company which is tax resident in Cyprus.
  • You must not be a tax resident in any other country.
  • You must not reside in any other single country for a period exceeding 183 days in aggregate.

In order to reside in Cyprus, you have a variety of options. These differ for EU nationals and non-EU nationals. It is also worth considering that, in some cases, after only 5 years of residency you can apply for citizenship through naturalisation and receive your Cypriot passport. We have included a brief summary of the most options below:

Residency procedure for citizens of the EU/EEA/Switzerland

  1. Registration of E.U. citizens (MEU1)

All citizens of the EU/EEA/Switzerland, as well as their family members who are also citizens of the EU/EEA/Switzerland, have the right to work and reside for a period of up to 3 months without any conditions or any formalities other than the requirement to hold a valid identity card or passport.

After 3 months they still have the right to work and live in the republic but just register their presence with the immigration office. They must hold a valid identity card or passport and:

  • be workers or self-employed persons in Cyprus; or
  • have sufficient resources for themselves and their family members not to “become a burden on the social assistance system” during their period of residence and have comprehensive sickness insurance cover in Cyprus.

Residency options available for non-EU nationals

  1. Starting a business
  1. Establishing a Foreign Interest Company (FIC)

Work and residency permits can be obtained for relevant employees and Directors, as well as their family members.

  • Establishment of a Small/Medium Size Innovative Enterprise (Start-up Visa)

The core goal of the Cyprus start-up visa scheme is to allow talented, non-EU entrepreneurs to reap the benefits of residing and working in Cyprus. There are two main schemes: (1) the Individual Start-up Visa Scheme; and (2) the Team Start-up Visa Scheme. This visa is available for one year, with the option to renew and allows you to work and reside in Cyprus.

  • Permanent Residence through Investment Programme (PRP)

Applicants must make an investment of at least €300,000 in one of the investment categories required. The most popular of which are real estate and investing capital into in a Cyprus company. They must also have an annual income of at least €50,000 and deposit a minimum €30,000 into a bank account in Cyprus, for a minimum period of three years.

  • Other less popular options available that our team can help with

There are less individuals using these permits due to their specific nature. However, for the right individual they can be the right choice. These include the Permanent Residence Permit on a Visitor Basis (Category F) Permit. This does not allow you the right to work but you can still receive income from overseas, such as a pension or dividends. There is also a Digital Nomad Visa, however the cap of the total amount of allowed applications has been reached and therefore this programme is currently unavailable.

If you would like to hear more about each option, please contact a member of the team here in Cyprus and we will be more than happy to run through the options in full detail with you and discuss what might be best for you.

What are the Advantages of Becoming a Cyprus Tax Resident?

Cyprus non-domicile status can be an effective means to optimise personal wealth planning. The advantages of becoming a Cyprus tax resident, an option for individuals not previously tax resident in Cyprus, include the following:

  1. Non-Domicile Status

The non-domicile tax regime is particularly interesting for individuals whose main source of income is not salary based. This is because the following sauces of income attract a 0% tax rate in Cyprus:

  • Dividends
    • Interest income
    • Capital gains, other than on the sale of immoveable property in Cyprus

There are also other tax advantages, including a low rate of tax on foreign pension income, as well as no wealth or inheritance taxes.

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

For those that do receive a salary, Cyprus has recently updated its income tax laws and now has some very attractive income tax exemptions for those Non-Domiciled Tax Residents who do take up employment in the Republic.

  1. The 50% exemption:

50% of the remuneration of employees whose first employment in Cyprus began on, or after, 1 January 2022 is exempt from income tax for a period of 17 years, provided that their annual remuneration exceeds €55,000, and the employees were not residents of Cyprus for a period of at least 15 consecutive years before the commencement of their employment in Cyprus.

  • The 20% exemption:

Individuals whose first employment in Cyprus began after 26 July 2022 and earn less than €55,000 are eligible for a 20%, or €8,550 exemption (whichever is lower) from their employment income, for a maximum period of 7 years provided that the employee was not a resident of Cyprus for a period of at least 3 consecutive years before the commencement of their employment in Cyprus.

  • 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.

If you are interested in making the most of the benefits outlined above and would like to hear more, please contact a member of our expert team who would be more than happy to outline how we can help you make the most of the fantastic tax efficiencies that Cyprus has to offer.

Launch Your Dreams in Europe: Portugal’s Start-Up Visa

Are you an aspiring entrepreneur with a groundbreaking idea and the drive to see it flourish? Look no further than Portugal’s Start-Up Visa! This initiative welcomes foreign innovators like yourself, offering a streamlined path to residency and the chance to establish your business in a thriving European hub.

Why Portugal?

Portugal has rapidly become a magnet for entrepreneurs and is lauded for its:

  • Supportive Ecosystem: A network of business incubators, co-working spaces, and government agencies provide guidance, resources, and funding opportunities to help your start-up take root.
  • Favourable Tax Environment: Portugal offers competitive tax rates for both companies and individuals:
    • Individuals: under certain conditions, individuals may benefit for the favourable tax regime called the NHR – see here for more details. Other advantages may still exist for those not eligible for NHR.
    • Corporate: Taxes from 12.5% apply to start-ups in Portugal mainland – however, making use of the Madeira International Business Centre is an alternative option which provides an attractive tax rate of 5%. Read here for more details.
      • Further, government support programs are available in Portugal to support start-ups.
  • High Quality of Life: Portugal boasts a stunning coastline, rich culture, and a welcoming population, making it an ideal place to live, work, and raise a family.
  • Doorway into Europe: a gateway into the world’s largest trading bloc with access to a favourable business with clients, suppliers, grants and beneficial tax regimes

Furthermore, Portugal is rapidly emerging as a significant player in the global start-up landscape, with several companies achieving unicorn status and attracting significant investment. This thriving ecosystem presents a compelling opportunity for ambitious entrepreneurs seeking to establish their businesses in Europe.

The Start-Up Visa: Your Gateway to Success

The Start-Up Visa streamlines the visa application process for foreign entrepreneurs, allowing you to:

  • Gain residency in Portugal: This visa allows you to live and work in Portugal, granting access to the European Union market. After living in Portugal for 5 years, you and your family can apply for citizenship or permanent residency.
  • Bring your family: You can extend your visa to include your spouse and dependent children.
  • Focus on your business: With residency secured, you can devote your energy to building your dream company.

Eligibility and Requirements

To qualify for the Start-Up Visa, your business must meet the following criteria:

  • Innovation: Your business idea must be deemed innovative by IAPMEI, the Portuguese public agency responsible for innovation in the economy and who evaluates applications. This typically involves presenting a unique product or service, deemed innovative, with high growth potential. Eligible criteria includes:
    • Opening or relocating a company in Portugal;
    • Focus on technology and knowledge;
    • Have the potential to attain, after five years after the incubation period, a turnover over €325,000 per year, and/or assets value over €325,000 per year.
  • Job creation: Your business plan should demonstrate the potential to create qualified jobs in Portugal.

Portugal has many incubators to mentor and support new businesses. Explore a certified incubator and ask for a quotation of services. A signed contract with an incubator will be required when submitting for this type of visa option. A complete list of eligible incubators for the purposes of the start-up visa may be found here (IAPMEI – Página Inicial).

Minimum Stay Requirements:

  • You must be present in Portugal, within a 24 months period, for 18 months in a row or 16 intermittent months to maintain your residency status.

Minimum Payments:

  • There is no minimum investment required for the Start-Up Visa, unlike other residency routes in Portugal. However, you must demonstrate sufficient funds to support yourself and your dependents for the first year (as referred above).

Evaluation of the Visa

IAPMEI reviews and approves applications for the start-up visa. The evaluation of the visa is based on the degree of innovation, the scalability of the business, the market potential, the capacity of the management team, the potential for creating qualified employment in Portugal and the relevance of the applicant in the team.

The processing time is at least 6 months to a year.

Taking the Next Step

At Dixcart Portugal, we are passionate about helping aspiring entrepreneurs like you navigate the complexities of international business ventures. We offer comprehensive guidance and to ensure a smooth and efficient journey.

Contact us today to schedule a consultation and learn how we can help you turn your vision into reality in Portugal (advice.portugal@dixcart.com). Together, let’s launch your success story in Europe!

Additional Notes:

It is important to remember that this information is for general informational purposes only and does not constitute advice. It is highly recommended to consult with a qualified professional on your specific situation.

Key Employee Initiative – Fast-track Work Permit in Malta for Non-EU Highly-Skilled Workers

What is the Key Employee Initiative?

The Key Employee Initiative (KEI) provides a fast-track work permit for highly specialised Third-Country Nationals (TCNs), who are employed in Malta.

The scheme enables work permits to be issued to key prospective employees, no longer than 5 working days from the date of application, under normal circumstances.

Third-Country Nationals

Third-Country Nationals require a single work permit to be able to obtain residence and be employed in Malta. This is because TCNs are not members of the EU or EFTA, and are therefore not able to move across borders, in the EU, without the proper documentation. 

However, TCNs who are high-skilled workers, are provided with a fast-track work permit service by the Key Employee Initiative. Under normal circumstances, the scheme will issue work permits in not more than 5 days, as detailed above. In contrast non highly specialised TCNs must wait for at least a couple of months.

Who is Defined as a Highly Skilled Worker?

Highly-skilled workers include individuals who possess advanced technical, academic and interpersonal skills. They usually flourish in the areas of; problem-solving, leadership, system improvement and creativity. Examples of highly-skilled workers include; university professors, engineers, biotech scientists, business directors, and IT experts. 

Criteria

Malta’s Key Employee Initiative (KEI), is available to highly technical or managerial professionals with the relevant qualifications and experience for the job they are applying for.

Eligible highly-skilled workers are required to meet the following requirements: 

  • Have valid travel documents.
  • Receive an annual gross salary of at least €45,000.
  • Be in possession of certified copies of qualifications and necessary work experience.
  • The employer must declare that the individual has the necessary credentials for the assigned role. Should the applicant wish to be employed by a Maltese company of which s/he is a shareholder or ultimate beneficial owner, s/he must have a fully paid up share capital of at least €500,000 OR must have made a capital expenditure of at least €500,000 to be used by the company (fixed assets only, rental contracts do not qualify).

Benefits:

The following benefits are available through Malta’s Key Employee Initiative:

  • The KEI is a fast-track version of the standard single work permit application, with applications being approved in just 5 days.
  • Applications can be submitted online, without the applicant needing to be present in Malta.
  • Approved applicants are issued with a residence permit valid for 1 year. This  can be renewed, subject to the presentation of a valid definite or indefinite contract, and an original ‘annual tax declaration form’, stamped by the Maltese Inland Revenue Department.
  • Visa-free travel within the 26 Schengen Area Countries, by virtue of the Maltese residence card. This is limited to a maximum of 90 days every 180 days.

Family Members of Work Permit Holders

Non-EU nationals who have been legally residing in Malta for over a year (in specific circumstances this may be reduced), are eligible to apply for the ‘reunification’ of family members. This includes spouses over the age of 21 and children under the age of 18.

Long-term Residents

Long-term residence status may be granted to persons legally residing in Malta for a continuous 5 year period.

A successful application requires; proof of continuous residence prior to the application date, and the ability to show stable and regular income of a stipulated amount. Dixcart can provide details of the other requirements, which include the need to have health insurance and attendance of a language and culture course.

Tax Treatment

  • Tax is charged at progressive rates (capped at a maximum of 35%), on Malta sourced income and capital gains, and on foreign source income (excluding foreign source capital gains), that is remitted to Malta.
  • No tax is chargeable on foreign sourced income that is not remitted to Malta.
  • Capital gains are tax-exempt in Malta, even if they are remitted to Malta.
  • Bank interest earned in Malta can be liable to withholding tax at 15%.
  • Long term residence permit holders are not entitled to benefit from the remittance basis of taxation and will be taxed on their worldwide income in Malta.

Case Study

Dixcart Malta provided advice to a UK citizen who was still living in the UK. An important benefit of the Key Employee Initiative is that it is possible to start the  process before the relevant individual has even arrived in Malta.

This highly-skilled professional, in the ICT industry, secured his position at a Maltese employer and decided to relocate to the island once he received the ‘Approval in Principal Letter’, confirming that his application met all of the requirements and had been successful.

After being provided with all of the essential documents, Dixcart Malta made the application, on behalf of the Employee and Employer and submitted all of the forms and evidence of experience, qualifications, and health insurance, to the Authorities. In addition, we even helped to find an apartment for the newcomer.

After receiving a final decision, the KEI had 90 days to relocate to Malta.

Another Set of Circumstances

Dixcart Malta can also provide support services, relating to the Key Employee Initiative, for TCN Employees and local Employers. There may be situations where positions cannot be filled by the local labour market and where suitable TCNs can fulfil the job in the EU with a fast-track Malta work permit, rather than the company remain with vacant positions.

Additional Information

For further information on the Key Employee Initiative, please do not hesitate to contact Jonathan Vassallo: advice.malta@dixcart.com at the Dixcart office, in Malta or your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC.

New More Accessible Fast-Track Work Permit in Malta

The Specialist Employee Initiative

A new Fast-track work permit has been introduced in Malta called the Specialist Employee Initiative (SEI). This route is applicable to specialised employees that are not eligible for the Key Employee Initiative (KEI), but still hold the relevant academic, vocational or technical skills in line with their employment offer in Malta. Applications for SEIs are filed in accordance with the Single Permit Regulations.

The introduction of the SEI demonstrates Malta’s commitment to attracting global talent, recognising the importance of simplifying application procedures for qualified foreign workers.

Third-Country Nationals

Third-Country Nationals (TCNs) require a single work permit to obtain residence and to be employed in Malta. This is because TCNs are not members of the EU or EFTA, and are therefore not able to move across borders, in the EU, without the proper documentation.

However, highly skilled TCNs benefit from a fast-track work permit service under this Specialist Employee Initiative.

Application Process

The processing time for this type of application typically takes around 15 days, after submission of the complete list of required documents.

The employer is required to email a completed application along with all necessary attachments in accordance with the relevant checklist. ‘Identitá’, the Government Agency overseeing this programme, will ask the applicant’s permission before submitting the application and supporting materials.

Upon receiving approval, the application will be processed in accordance with set protocols. Both the company and the candidate will receive an informational email and an acknowledgement, along with additional instructions on how to pay the application fee during the biometrics stage.

Any missing documents can result in delays or application rejection. It is important to ensure that all mandatory documents are submitted as per the checklist.

Once a decision is made on the application, both the applicant and the employer are informed of the outcome via email.

Eligibility and Requirements

In order to be eligible to apply for the SEI application an individual must:

  • Have a signed contract with a Maltese company;
  • Have an annual gross salary of at least €25,000;
  • Be in possession of either
    • (i) an MQF level 6 or higher in an area directly related to the job offer or
    • (ii) skill qualifications together with a minimum of 3 years’ experience in a position which is directly related to the job offer.
  • Present previous employment contracts (signed by both employer and employee).
  • Provide their employment history, issued and officially certified (stamped or legalised) by the official employment authority in the country where the employment took place.
  • Reference letters by former employer/s. Reference letters must show the start and end dates and details of the work carried out. The letters should contain clear contact details of the referee including a valid email address, postal address and contact number.

Typical documents needed with the application are:

  • Full copy of passport
  • CV
  • Declaration of Suitability
  • Lease Agreement & Housing Approval
  • Health Screening
  • Health Insurance

Visa duration and conditions

A residence permit will be granted to successful applicants for a period of one year. If the employee remains in compliance with the eligibility criteria and his/her employment contract applies to all periods of validity, this authorisation may be renewed for an additional period of up to three years.

Tax Treatment

  • Tax is charged at progressive rates (capped at a maximum of 35%), on Malta sourced income and capital gains, and on foreign source income (excluding foreign source capital gains), that is remitted to Malta.
  • No tax is chargeable on foreign sourced income that is not remitted to Malta.
  • Capital gains are tax-exempt in Malta, even if they are remitted to Malta.
  • Bank interest earned in Malta can be liable to withholding tax at 15%.
  • Long-term residence permit holders are not eligible for the remittance basis of taxation and will be taxed on their worldwide income in Malta.

Conclusion

The introduction of this programme introduces an option for highly skilled third country nationals to obtain a work and residence permit in Malta, 15 days after the submission of the application and relevant documentation. Identitá have recognised the increased demand for such a work permit and this initiative will help improve processing time and efficiency.

Additional Information

For further information on the Specialist Employee Initiative, please do not hesitate to contact Jonathan Vassallo: advice.malta@dixcart.com at the Dixcart office, in Malta or your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC.

UK Non-Domiciled Individuals Seeking to Relocate to Cyprus

Introduction

Following the announcement in March 2024 from the UK’s Treasury Department, that the current UK non-domiciliation rules will cease to exist from 6 April 2025, many UK non-domiciled residents may take the decision to relocate to a more tax efficient jurisdictions.

The Benefits of Cyprus

  • Attractive tax incentives for individuals wishing to become Cyprus residents
  • Excellent education infrastructure
  • Reasonable cost of living
  • High quality public and private health care services
  • Advanced infrastructure of services
  • A warm and friendly community in which to live
  • Simple tax regime that is fully EU and OECD compliant
  • Well drafted laws on Corporate and Commercial matters
  • Easy access to international litigation and arbitration

Moving to Cyprus

There are various options in terms of moving to Cyprus, as outlined below:

EU Non-Domiciled UK Residents Moving to Cyprus.

Nationals of EU Member States have the right to move freely within the European Union and to enter and reside in any EU Member State. This right to freedom of movement is guaranteed by article 21 of the treaty on the functioning of the EU (TFEU).

EU and EEA Citizens entering Cyprus to work, stay, or remain as visitors for more than 3 months on the island need to register for a residence permit for EU citizens. The registration certificate they get is commonly known as Yellow Slip.

Third country non-domiciled UK residents moving to Cyprus.

A. Moving to Cyprus from the UK as an Investor

The recently revised Residency by Investment programme allows foreign nationals to obtain permanent residency by investing in a Cypriot property worth at least €300,000, plus VAT. Applicants must also have an annual income of at least €50,000, plus €15,000 for a spouse and €10,000 for each dependent child or family member included in the application.

The applicant and his/her 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 the policy, as detailed below.

B. Living in Cyprus with a Temporary Residence Permit

1. Establishment of 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 route 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:

  • Third country shareholder(s) must own more than 50% of the total share capital of the company.
  • There must be a minimum investment of €200,000 or €260,000 (depending on the circumstances) into Cyprus by third country shareholder(s). This investment can be used later to fund future expenses incurred by the company when it is established in Cyprus.
2. Acquiring a Temporary Residence Permit as an Employee at a Foreign Interest Company

Employees at Foreign Interest Companies and their family members can acquire temporary residence and work permits which are renewable.

3. Temporary / Retirement / Self-Sufficiency Residence Permit

The Cyprus Temporary Residence Permit is an annually renewable self-sufficiency visa that allows an individual and their qualifying dependants to live in Cyprus as a visitor, without employment rights.

The main qualification requirements are as follows:

  • Minimum annual income (sourced from outside Cyprus) of €24,000, which increases by 20% for a spouse and by 15% for each dependent child.
  • A title deed or rental agreement for a residential property in Cyprus that is for the sole use of the applicant and his/her family.
  • A certificate of ‘no criminal record’ and of not being under investigation for criminal offences, certified by the relevant authorities in the country where the applicant is currently residence.
  • Private medical insurance.
  • An original medical examination certificate to confirm that the applicant does not have certain medical conditions.

It is essential that the holder of a Cyprus temporary residence permit should not stay outside of Cyprus for more than three months at a time, which could result in the permit being rejected or revoked.

Additional Information

For further information, please contact the Dixcart office in Cyprus: advice.cyprus@dixcart.com.


Tax Efficiencies Available in Cyprus: Individuals and Corporates

Why Cyprus?

Cyprus is an appealing European jurisdiction, located in the eastern Mediterranean Sea offering a warm climate, attractive beaches and the perfect balance of cosmopolitan living and rural villages. Strategically located at the crossroads of three continents, Cyprus is accessible from Europe, Asia and Africa. Nicosia is the centrally located capital of the Republic of Cyprus however, the growing financial hub is Limassol on the southern coast. The official language is Greek, with English also being widely spoken. Cyprus offers a palette of both corporate and personal tax incentives for expatriates and high net worth individuals relocating to Cyprus. Cyprus has a favourable business environment and, as a result, has become an attractive an international business hub.

Are you looking to relocate your business and/ or start a new business in Cyprus? Maybe you’re considering setting up a holding company or restructuring the fiscal position of a family office structure? If you are, please consider the below information and become convinced of a great way to optimize your business structure 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:

  1. 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.

  1. Employment Income Tax Exemption

New incentives for first employment in Cyprus

The 50% exemption:

As from 1 January 2022, 50% of the remuneration of employees whose first employment in Cyprus began on, or after, 1 January 2022 is exempt from income tax for a period of 17 years, provided that their annual remuneration exceeds €55,000 (previous threshold €100,000), and the employees were not residents of Cyprus for a period of, at least, 15 consecutive years before the commencement of their employment in Cyprus.

In cases where in a tax year the relevant conditions are not satisfied (e.g., annual remuneration is less than €55,000) the above-stated exemption will not be granted for that specific tax year. This exemption is available for a period of up to 17 years.

The 20% exemption:

Individuals whose first employment in Cyprus began after 26 July 2022 and earn less than €55,000 are eligible for a 20%, or €8,550 exemption (whichever is lower) from their employment income, for a maximum period of 7 years provided that the employees were not residents of Cyprus for a period of, at least, 3 consecutive years before the commencement of their employment in Cyprus.

This exemption can be claimed from the year following the year of commencement of employment in Cyprus.

  1. 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

  1. Corporate Tax Rate

Cypriot companies enjoy a 12.5% rate of tax on trading, and a zero rate of capital gains tax.

  1. 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

  1. 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.

Additional Information

For further information about the attractive tax regimes available to individuals and companies in Cyprus, please contact the Dixcart office in Cyprus: advice.cyprus@dixcart.com.

 

The Ultimate Guide to Relocating to Switzerland

Switzerland, with its snow-capped peaks, pristine lakes, and efficient infrastructure, has long been a dream destination for many individuals seeking a balance between a high-quality lifestyle and professional opportunities. As one of the most prosperous and picturesque countries in Europe, it also attracts individuals due to its strong economy, political stability, and exceptional living standards. If you are considering making Switzerland your new home, here’s the ultimate guide to navigating the logistics of working and living in this alpine haven.

You may find also find this Dixcart Swiss Article of interest to read: Switzerland – Could this be your Next Move? – Dixcart

Relocating Logistics

Visa and Residency

Before planning your move, it is essential to understand Switzerland’s visa and residency requirements. Depending on your nationality and purpose of stay, you might need to obtain a visa or a residence permit. Ensuring you have the necessary paperwork in order, will smooth the transition process.

Accommodation

Switzerland boasts a diverse housing market, from urban apartments to picturesque countryside chalets. Local real estate agents and online platforms can help you find the perfect place to call home.

Healthcare System

Switzerland is renowned for its excellent healthcare system, which is often ranked among the best in the world. Familiarise yourself with the country’s health insurance requirements and the different insurance providers available, to ensure that you and your family have comprehensive coverage.

Working in Switzerland

Job Market

Switzerland is home to a thriving economy, particularly in sectors such as finance, pharmaceuticals, and technology. Understanding the job market, networking with professionals in your field, and researching employment opportunities will increase your chances of finding a fulfilling career.

This Dixcart Article includes a useful section regarding working in Switzerland: How Can I Relocate to Switzerland and What Help is Available? – Dixcart

Work Culture

Swiss work culture is known for its punctuality, precision, and strong work ethic. It’s crucial to familiarise yourself with the local customs and etiquette, including the importance of maintaining professionalism and respecting hierarchical structures within the workplace.

Taxes and Finance

Switzerland has a well-established tax system, but it can be complex for newcomers. Educate yourself on the tax regulations and financial planning to ensure compliance and make the most of the various benefits offered to residents.

It is worth seeking professional advice and the Dixcart office in Switzerland can help guide you regarding the various taxes: advice.switzerland@dixcart.com

Living in Switzerland

Cultural Immersion

Embrace the Swiss way of life by participating in local cultural activities, festivals, and events. Learning one of the country’s official languages—German, French, Italian, or Romansh can also help you integrate more seamlessly into the community.

Outdoor Lifestyle

Switzerland’s breathtaking natural landscapes offer an abundance of outdoor activities, from skiing and snowboarding in the winter to hiking and swimming in the summer. Embrace the Swiss passion for nature and adventure by exploring the country’s extensive network of hiking trails and ski resorts.

Community Engagement

Swiss communities value active participation and engagement. Get involved in local community initiatives, clubs, or volunteer organisations to build meaningful connections and foster a sense of belonging in your new surroundings.

For Expert Assistance, Reach Out to advice.switzerland@dixcart.com

Relocating to Switzerland can be a rewarding and enriching experience, but it requires thorough preparation and a comprehensive understanding of the country’s customs, laws, and lifestyle.

For personalised guidance and professional support in navigating the intricacies of the relocation process, reach out to our expert advisers at advice.switzerland@dixcart.com. Our team at Dixcart Switzerland is dedicated to ensuring a seamless transition and helping you make the most of your Swiss adventure.

Malta

Moving to Malta – Using the Isle of Man to Structure Your Assets Efficiently

Located in the heart of the Mediterranean, between the north of Africa and southern Europe, Malta is a modern international commercial hub with a global draw.

Malta boasts a diverse economy with well-developed Financial Services, Fintech, Science and Technology, eGaming, Maritime Services and Aviation sectors. Additionally, the island offers extensive Residency routes available, Schengen area status, fantastic travel links and potentially beneficial tax regime. For these reasons and many more, Malta is a destination of choice for wealthy families, entrepreneurs and businesses around the world. 

Malta offers people relocating to her shores a very attractive Non-Domicile regime that provides individuals with a great deal of flexibility when it comes to structuring their financial matters – this is precisely where the Isle of Man can offer clients a platform for optimising their wealth.

In this article we take a brief look at how Dixcart can assist with moving to Malta and how those individuals can utilise the Isle of Man to protect and grow generational wealth, covering:

  1. How to Become a Maltese Tax Resident?
  2. What are the Tax Rules of the Maltese Non-Domicile regime?
  3. How Maltese Non-Domicile Individuals Utilise the Isle of Man for Wealth Planning?
  4. How Dixcart can Support your Move to Malta & Wealth Planning Goals

1. How to Become a Maltese Tax Resident?

There are two distinct groups of people when we consider the method of becoming Malta Tax Resident – these are 1) EU / EEA / Swiss Nationals, and 2) Third Country Nationals. Importantly, for the purposes of this article, where either type of individual does not intend to remain in Malta permanently and has no substantial connection to Malta, both groups may be deemed a Tax Resident Non-Domiciled individual. There are also compelling Residency options available to each group which offer the same benefits and broadly have the same requirements.

Malta is a member of the European Union (EU) and European Economic Area (EEA). As such, EU / EEA Nationals can live, work and study in Malta indefinitely without a Visa or Work Permit. Swiss Nationals also enjoy this right. These individuals can apply for the Residence Programme via an Authorised Registered Mandatory, such as Dixcart Malta. The Residence Programme offers a special tax status to successful applicants who meet the requirements.

Third Country Nationals will be required to take part in a programme such as the Global Residence Programme or successful applicants also gain a special tax status and are granted a residence permit which also extends to their dependents, including spouses and children. The special tax status received under either programme entitles the individual to a beneficial flat rate of 15% on foreign source income remitted to Malta, with the possibility of claiming double taxation relief where an appropriate Double Tax Treaty is in place. Income that arises in Malta is taxed at a flat rate of 35%. The beneficial rate is subject to a minimum yearly tax contribution of €15,000.

The Malta Residency Programme and Global Residence Programme requirements include:

  • Applicants must pay a one-time non-refundable registration fee of €6,000 to the Maltese Government. This is reduced to €5,500 where the Qualifying Property Holding is purchased in Gozo or the South of Malta.
  • Not have benefitted from a number of previous or existing Malta regimes.
  • Evidence of a Lease Agreement and Rental Declaration, or Purchase Agreement relevant to a Qualifying Property Holding. A Qualifying Property Holding requires a minimum investment in a Maltese property of €275,000, or €220,000 if the property is in Gozo or the South of the island. In the instance of a Rental Agreement, rent must cost not less than €9,600 per annum, or €8,750 if the property is in Gozo or the South of the island. The property cannot be let or sub-let.
  • Evidence of self-sufficient means of subsistence (e.g. bank statements, pension, secure bonds, etc).
  • Posses a valid travel document.
  • Evidence of comprehensive health insurance OR Certificate of Entitlement issued by the Entitlement Unit. Must provide cover within the EU for the applicant and all dependents.
  • Be proficient in one of Malta’s official languages (English is an official language of Malta).
  • Applicants and dependents over 18 years of age must satisfy the fit and proper person requirements.
  • Submit an Annual Return – with any material changes that affect the beneficiary’s special tax status.
  • Not spend more than 183 days in any other jurisdiction, in any single calendar year.

2. What are the Tax Rules of the Maltese Non-Domicile regime?

Liability to Maltese Income Tax arises in three forms, dependent on the Tax Residency and Domicile status of the individual – these are on a Worldwide, Remittance or Territorial basis.

Ordinary Residents of Malta who are Tax Resident and Domiciled are taxed on their worldwide assets; meaning that all Income and Capital Gains are subject to Maltese taxation regardless of where they arise or are received. This also applies to persons who hold the status of Long-term Resident or are in possession of a Permanent Residence Certificate or a Permanent Residence Card.

Maltese Ordinary Residency status is determined by a question of fact, relating to the length of stay along with personal and economic ties. Factors which the authorities will consider, include:

  1. Permanent or Indefinite Basis: Individuals living in Malta permanently or for an indefinite period are typically considered ordinarily resident.
  2. 183 Day Requirement: If an individual stays in Malta for more than 183 days in a single year they may be deemed Ordinary Resident.
  3. Regularity of Stays: Persons who do not meet the 183-day requirement, but who regularly visit over a long period of time e.g. over 3 years, can also be considered Ordinarily Resident.
  4. Personal and Economic Ties: Establishing personal and economic ties in Malta is a significant factor in determining Ordinary Residency e.g. purchasing a family home etc.

The Maltese authorities do not define Domicile by nationality, but where the individual considers their permanent Home i.e. where the person ‘belongs’, which implies more significant ties than Residency alone. This can be the individuals Domicile of Origin i.e. normally the Domicile of their parents, regardless of the country where the individual is born. An individual may acquire a Domicile of Choice if they take up Residence in a country with the intention of making it their permanent home. However, they do not acquire Domicile status if they intend to return to their country of Domicile or resettle in another someday, even where the period is long or indefinite. No person can be without a Domicile, and no person can have more than one Domicile at the same time.

A person that is an Ordinary Resident but not Domiciled in Malta is taxed under the Remittance Basis, and therefore:

  • All income arising in Malta is subject to tax, regardless of where it is received.
  • Income arising outside Malta is subject to Maltese tax only if and to the extent that it is received in Malta.
  • Capital gains arising outside Malta are not subject to tax, even if they are received in Malta.

Individuals taxed under the Remittance Basis are subject to the special rule providing for a minimum tax liability of €5,000 per annum (this minimum tax is different to the Global and Residence program which is 15%).

Unlike many equivalent Non-Domicile regimes, an individual can remain Non-Domiciled in Malta indefinitely.

This means that where the Tax Resident Non-Domiciled individual can show that monies received in Malta originate from assets held abroad as capital e.g. inheritance, proceeds from the sale of capital assets etc. they will be regarded as remittances of capital and will not suffer Maltese tax.

Dixcart Malta are equipped to provide Tax Advice regarding Maltese taxation and the Maltese Non-Domicile regime. If you would like to discuss how the regime works and any opportunities relevant to your circumstances, please get in touch with Jonathan Vassallo at Dixcart Malta.

3. How Maltese Non-Domicile Individuals Utilise the Isle of Man for Wealth Planning?

The Isle of Man is globally recognised as an international financial centre of excellence, boasting a sophisticated legal and regulatory system, a developed professional services industry and a long running heritage in Private Client and Corporate planning.

The Isle of Man was named ‘Best International Financial Centre’ at the prestigious International Investment Awards 2023, beating off stiff competition from Jersey and Guernsey.

The island is a self-governing Crown Dependency which makes its own laws. The Statute book and Case Law is modern and business friendly yet enduring, with a wide array of corporate entities and Trusts available. The jurisdiction is also politically agnostic and therefore clients can take comfort from the stability and reliability offered.

The island also sets its own tax regime and offers headline rates which include:

  • 0% Corporate Tax
  • 0% Capital Gains Tax
  • 0% Inheritance Tax
  • 0% Withholding Tax on Dividends
  • Isle of Man companies are able to register for VAT, and businesses in the Isle of Man fall under the UK’s VAT regime.

Owing to the attractive neutral tax regime, Non-Domiciled individuals seeking to live and work in Malta can potentially structure their non-Maltese assets in such a way that facilitates optimal growth via a potential nil rate in the Isle of Man, remitting withdrawals of capital to Malta free from Maltese taxation. Jonathan Vassallo at Dixcart Malta can provide certainty regarding the Maltese tax treatment of your potential Isle of Man structuring in this regard.

Taxation is a complex area and professional Tax Advice should always be sought before establishing any offshore structure.

4. How Dixcart can Support your Move to Malta & Wealth Planning Goals

After more than 50 years, the Dixcart Group remains proudly privately owned by the same family. the Group consists of 7 offices across the globe, including both Malta and the Isle of Man. Dixcart are very well positioned to assist clients and their advisers who are considering moving to Malta and seeking to structure their non-Maltese assets, or participation within a Maltese business, in a tax efficient manner via an Isle of Man structure.

Dixcart Malta are experts in all Residency routes available and are Licensed to act as Authorised Registered Mandatory for clients. Further, Dixcart Malta can provide Tax Advice for those looking to take advantage of the very beneficial Non-Domicile regime within Malta.

Dixcart Isle of Man are a Licensed and Regulated Trust and Corporate Services Provider that has developed an extensive range of services over its 30+ years of operation. Our team on the Isle of Man consists of professionally qualified experts and senior employees who possess a wealth of experience. This means that our Isle of Man office can support your corporate and/or Trust planning, at every stage.

Get in Touch

If you would like to discuss how our Dixcart can support your plans regarding Malta and the Isle of Man, please feel free to get in touch with Jonathan Vassallo of Dixcart Malta or Paul Harvey of Dixcart Isle of Man via:

Dixcart Malta: advice.malta@dixcart.com

Alternatively, you can connect with Jonathan Vassallo on Linkedin.

Dixcart Isle of Man: advice.iom@dixcart.com

Alternatively, you can connect with Paul Harvey on LinkedIn.

Dixcart Management (IOM) Limited is Licensed by the Isle of Man Financial Services Authority

Dixcart Management Malta Limited Licence Number: AKM-DIXC-23

Malta

The Benefits of Malta’s Highly Qualified Persons Programme

Malta, a charming Mediterranean island nation, has become increasingly popular among expatriates and professionals seeking to relocate to a vibrant, culturally rich, and economically stable country.

One of the key factors driving this interest is the Highly Qualified Persons Programme (HQP), introduced by the Maltese government to attract talented individuals and strengthen its economy. This programme offers a range of benefits to eligible applicants, making it an attractive option for highly qualified individuals from around the world.

What is the Criteria?

In order to be eligible for the HQP programme, you would need comply with the following rules below:

  1. Eligible Employment:  An individual must be employed in an eligible office with a company that is licensed, and/or recognised by the Competent Authority regulating the specific sector.  Qualifying roles typically include positions in fields such as; finance, gaming, aviation, and other sectors that are in high demand in Malta.
  2. Minimum Qualifications and Salary: You should possess specific qualifications and skills that are relevant to your profession. Additionally, your annual gross salary should meet a minimum threshold, which may vary depending on the specific eligibility criteria at the time of your application. As of October 2023, the minimum salary requirement is €93,669 for the basis year 2023.
  3. Health Insurance: You are required to have valid health insurance that covers you and any accompanying dependents.
  4. Residential Property: HQP applicants are usually required to either purchase (only available for EU Nationals), or rent a qualifying property in Malta, which serves as their primary residence.
  5. Clean Criminal Record: Applicants and their dependents should not have any criminal convictions.
  6. Genuine Link to Malta: You should establish a genuine link to Malta, which may include having a physical presence in Malta and being an active part of the community.
  7. Application Fees: Applicants need to be prepared to pay the necessary application and processing fees when applying for the programme.

What are the Benefits?

Tax Incentives

The HQP program is well-known for its attractive tax incentives, which are among the most compelling benefits for applicants. Successful candidates can enjoy a flat tax rate of 15% on their Malta-source income, provided it meets the eligibility criteria. Income exceeding €5,000,000 is exempt from income tax in Malta.

The Malta tax benefits under this scheme apply to EEA and Swiss nationals for a maximum consecutive period of 5 years, preceding the first year of assessment and to third country nationals for a maximum consecutive period of 4 years.

EEA/Swiss nationals who take advantage of this tax benefit shall be eligible, upon application, for a two-time extension of 5 years, making the qualifying period a maximum of 15 years of assessment and offering significant savings compared to other countries, with higher income tax rates.

Third country nationals may extend their programme twice by another 4 years, bringing their maximum time in Malta to 12 years.

The tax benefits make Malta particularly appealing for high-earning professionals and entrepreneurs who want to optimise their financial planning.

Diverse Business Opportunities

The HQP programme is limited to specific industries, including; Financial Services , Research & Development, Gaming, and Aviation and Oil and Gas. Malta has established itself as a hub for various industries, offering ample opportunities for entrepreneurs and skilled professionals. The Government is keen to attract foreign investment, leading to a business-friendly environment that promotes innovation and growth.

Education Opportunities

The HQP programme offers access to Malta’s high-quality education system. International schools in Malta provide an excellent education for expatriate children, often following international curricula. In addition, Malta’s two universities, the University of Malta and the Malta College of Arts, Science and Technology, offer a wide range of programmes and research opportunities, making it an excellent destination for those seeking advanced academic degrees.

Quality of Life in Malta

Malta offers an exceptional quality of life. Its pleasant Mediterranean climate, picturesque landscapes, and a rich cultural heritage, make it an ideal place to live and work. The country boasts a strong sense of community, a safe environment, and a high standard of healthcare and education. Furthermore, Malta’s strategic location makes it an excellent hub for travel and exploration of the broader European region.

Malta’s historical and cultural heritage is one of its most distinctive features. The island is home to numerous UNESCO World Heritage Sites, including the ancient city of Valletta. Its vibrant arts scene, diverse festivals, and cuisine, attracts individuals looking for a rich cultural experience. Malta’s multicultural society also welcomes people from various backgrounds, creating a dynamic and inclusive environment.

Conclusion

The Highly Qualified Persons Programme in Malta is a remarkable opportunity for highly skilled professionals and their families to move to a Mediterranean island.

With its enticing tax incentives, EU membership, diverse business opportunities, and an exceptional quality of life, Malta has become a top destination for those looking to enhance their personal and professional lives.

The programme’s inclusivity, and the rich sunny weather on offer, also make Malta an appealing choice for those seeking a new place to call home while advancing their careers and quality of life.

How Dixcart can help?

As a Licensed Residency Agent, Dixcart can assist in the submission and management of the HQP application, and ensure a smooth and steam lined process, making it as straight forward as possible.

For further information about the benefits of the HQP, please contact Jonathan Vassallo, at the Dixcart office in Malta: advice.malta@dixcart.com.

Alternatively, please speak to your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC.

Programmes to Move to or Become Tax Resident in Cyprus

Background

Numerous tax advantages exist in Cyprus, for companies and previously non-Cypriot resident individuals. Please see article: Tax Efficiencies Available in Cyprus: Individuals and Corporates.

Individuals

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.

  1. 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. 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.

  1. 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, 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.

It is worth noting that each year the government only issues a set number of visas. This number is at the discretion of the government and each year the scheme has been in place the cap has been reached.

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.