Industry · E-commerce & FBA
Cyprus for FBA and DTC brand owners — structure in Cyprus, fulfilment in EU FBA
Built for 7- and 8-figure Amazon FBA brand owners and Shopify DTC operators. Move the entity, the IP and the founder to Cyprus — keep fulfilment in Amazon's EU centres or your existing 3PL. 15% corporate, single OSS for EU VAT, 0% non-dom dividends.
The Cyprus stack
Same three layers, applied to e-commerce & amazon fba
Cyprus Ltd
Corporate income tax (2026)
15%
+ IP Box
Qualifying-IP effective rate
~3%
+ Non-dom founder
SDC on dividends, 17–27 yrs
0%
All-in for the founder
≈3% on profit · 0% on draw
15%
Corporate tax on brand profit
~3%
IP Box on owned brand IP
0%
Non-dom on dividends
What you save
Worked example: €8m-revenue Amazon FBA brand, 18% net margin
Single-brand FBA operator at €8,000,000 revenue, 18% net margin = €1,440,000 profit. Founder draws €400,000 of dividends per year. Compares a German GmbH (current) versus Cyprus Ltd with founder relocated.
Illustrative figures based on the Cyprus 2026 framework. Your actual outcome depends on home country, structure, family situation and substance — modelled on the call.
Annual net saving
€100,000+ / year
Over the 17-year non-dom window: ≈ €1.7m without IP Box, plus the structural 0% CGT when the brand is sold to an aggregator or strategic.
Today
- Profit before tax€1,440,000
- German corporate + trade tax (~30%)−€432,000
- Net for dividends€1,008,000
- German Abgeltungsteuer on €400k dividends (26.375%)−€105,500
- Net to founder€294,500
After Cyprus
- Profit before tax€1,440,000
- Cyprus corporate tax (15%)−€216,000
- Net for dividends€1,224,000
- Cyprus non-dom SDC on €400k dividends€0
- GESY 2.65% (capped at €180k)−€4,770
- Net to founder€395,230
Why Cyprus, specifically
Three things Cyprus does for e-commerce & amazon fba that nowhere else in the EU does at once.
Tax
15% corporate tax on brand profit
Legal
Common-law contracts, English-language
Banking & Ops
Single OSS for all EU B2C VAT
“They helped me set up a holding company in Cyprus. The process was straightforward and their knowledge of international tax is impressive.”
How it works
Three steps from decision to operational.
Strategy call
We map your brand, marketplaces, supplier base, current entity and IP ownership. Honest answer on whether Cyprus is right for your specific brand. Written scope within 24h.
Cyprus Ltd live
Incorporation in 5–10 business days. Tax & VAT registration. OSS opt-in. UBO filed.
Banking + PSP onboarding
Cyprus banking opened. Stripe / Adyen / Klarna onboarded. Wise / Revolut Business as supplemental rails. Multi-currency reconciliation routine handed over to your accountant.
Total realistic timeline: 2–3 months from decision to fully operational, with most of that being your own travel and apartment-hunting rather than the legal work.
vs the alternatives
Why Cyprus over Malta, Estonia, the UAE and Portugal — for e-commerce & amazon fba.
vs Malta. Malta's 6/7 refund mechanism produces a similar net rate (~5%) but only crystallises on dividend distribution and after a 12-month refund cycle, with banking that is materially harder to onboard. Cyprus is a flat 15% headline with the IP Box adding genuine ~3% effective for qualifying software income — simpler to defend, faster to bank.
vs Estonia. Estonia's deferred-tax regime is elegant for purely retained-profit businesses but levies 22% on every distribution — meaning when you draw cash, you pay. Cyprus non-dom dividends are 0% for 17–27 years. For founders who actually want to take money out, Cyprus wins.
vs UAE. The UAE's 9% corporate rate and 0% personal tax are attractive — but it is non-EU, GDPR-foreign and increasingly procurement-blocked by EU enterprise customers over Schrems II. Cyprus gives you the EU passport, native GDPR status and common-law contracts in English — without giving up much on the tax side.
vs Portugal. Portugal's NHR closed to new applicants in 2024. Its IFICI successor is narrow and excludes most pure digital-revenue businesses. Cyprus's non-dom is statutory law with bipartisan stability, recently strengthened (not weakened) by the 2026 reform with the 27-year extension election.
What we actually do
The full scope, fixed-fee, signed before any payment.
One licensed Cyprus lawyer accountable end-to-end. No hand-offs, no hourly billing, no surprise disbursements. Each scope is signed in writing within 24 hours of the call.
Cyprus brand-holding Ltd set-up
Incorporation, registered office, beneficial-owner register, tax & VAT registrations, OSS opt-in. Memorandum & Articles tailored to a 1–3 founder brand-owner structure with leadership ESOP support.
From €1,400 fixed
Trademark + brand-IP migration
Assignment of EUTM, USPTO, UK and other-jurisdiction trademarks into the Cyprus Ltd. Domain transfer. Packaging, photography and copyright-protected content assigned via written deeds. Brand-protection legal pack.
Founder relocation + non-dom
Pink Slip / Yellow Slip residency, 60-day rule structuring, non-dom certification, year-1 personal tax return locking in 0% SDC on dividends.
From €1,400
Amazon Seller Central + Shopify migration
Switching the legal entity on Amazon Seller Central to the Cyprus Ltd, updating bank-account verification, VAT-number changes, and Shopify merchant entity migration with PSP re-onboarding.
Cyprus structuring for e-commerce & amazon fba, done properly.
A 30-minute call with a licensed Cyprus lawyer. Honest answer on whether Cyprus fits your specific situation, written scope and fixed-fee quote within 24 hours. No obligation, no follow-up loops.
A few questions we hear most
Will my Amazon Seller Central account survive the entity change?
Yes — provided the change is staged correctly. Amazon supports legal-entity changes on Seller Central with proper documentation (incorporation cert, tax IDs, bank verification, ID for new beneficial owners). We provide the doc pack and sequence the change so settlements aren't frozen and new ASINs aren't blocked. Typical timeline: 2–4 weeks from change initiation to fully verified.
Do I have to physically move my inventory?
No. Inventory stays in Amazon EU FBA centres or your existing 3PL. Only the contracting / billing / IP-owning entity moves to Cyprus. We re-paper supplier and 3PL contracts to the Cyprus Ltd, but physical fulfilment continues uninterrupted.
What about VAT registrations in countries where I store inventory?
If your inventory is stored in Germany, France, Italy, Spain or Poland (typical pan-EU FBA), you need local VAT registrations there regardless of corporate domicile. The OSS does not replace those local registrations — it covers cross-border B2C only. We coordinate with your VAT specialist or refer one in.
Can the IP Box apply to my brand?
Trademarks themselves are not qualifying IP-Box assets under the post-Action-5 framework. What can qualify is software-driven systems your brand owns: custom Shopify theme code, recommendation engines, proprietary CRM logic, fulfilment-tracking software, copyright-protected content libraries (recipe books, instructional videos, courses bundled with products). We map your actually-qualifying assets honestly — over-claiming on "the brand" loses the claim on audit.
6 more questions answered on the call. Book a slot →
Keep reading
Deeper guides for e-commerce & amazon fba
- Cyprus corporate tax 2026The complete framework: 15% rate, IP Box, group relief, 7-year loss carry-forward.→
- Cyprus VAT & OSS — practical guideB2B reverse-charge, B2C OSS, multi-country pan-EU FBA inventory storage.→
- Non-dom status explained simplyThe 17-year window of 0% on dividends, what changed in 2026.→
- Opening a Cyprus business bank accountBank-by-bank realistic timelines and the e-commerce KYC pack that gets accounts opened.→
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Page last reviewed April 2026. Estimates only — not legal, tax or financial advice.