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Industry · Funds & Family Offices

Cyprus for funds, family offices and HNWIs — one of the cleanest non-dom + EU-fund regimes left

0% on worldwide dividends and interest as a non-dom for 17–27 years. 0% capital gains on non-real-estate securities, structurally. RAIF regulated funds with EU passporting. The 60-day rule for genuinely mobile principals. Built for serious capital, not lifestyle marketing.

The Cyprus stack

Same three layers, applied to funds & family offices

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

Cyprus Bar AssociationregulatedPhilippou Law Firm · est. 19844.9across 100+ reviews

0%

Non-dom on global dividends/interest

0%

CGT on non-RE securities

17–27 yrs

Non-dom window

What you save

Worked example: UK HNWI with €4m portfolio, €600k of annual income (post-non-dom abolition)

UK-resident HNWI with €4,000,000 globally diversified portfolio yielding €120,000 of annual dividends + €60,000 interest, plus €420,000 of investment / consulting / fund-distribution income. Compares the post-2025 UK regime versus relocating to Cyprus as a non-dom.

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

€150,000+ / year

Over the 17-year non-dom window: ≈ €2.5m+ over 17 years before reinvestment compounding, plus 0% CGT on portfolio rebalancing exits.

Today

  • Total income€600,000
  • UK income tax + NIC (≈47% blended top rate)−€260,000
  • Net to family€340,000

After Cyprus

  • Total income€600,000
  • Cyprus tax on €120k dividends (non-dom SDC)€0
  • Cyprus tax on €60k interest (non-dom SDC)€0
  • Cyprus PIT on €420k other income (≈25% blended)−€105,000
  • GESY 2.65% (capped at €180k)−€4,770
  • Net to family€490,000

Why Cyprus, specifically

Three things Cyprus does for funds & family offices that nowhere else in the EU does at once.

Tax

0% non-dom on worldwide dividends + interest

As a Cyprus non-dom, 0% Special Defence Contribution on global dividends and interest income for 17 years (extendable to 27 under €250k-per-5-year-block elections). Pure GESY 2.65% applies, capped at €180k of total income. No further income-tax layer on dividends.

Legal

RAIF / AIF / AIFLNP regulatory framework

Cyprus offers the RAIF (Registered AIF, no direct CySEC authorisation, must be marketed only to professional investors), AIF (full CySEC authorisation, retail or professional), and AIFLNP (limited-number-of-persons, <50 investors). EU-passportable for AIFMD-compliant managers.

Banking & Ops

Private banking that actually opens

Bank of Cyprus Private and Hellenic Private have functional HNWI onboarding for properly-documented relocators. Source-of-funds, tax-residency and KYC packs prepared in advance reduce onboarding to 4–8 weeks instead of the 6+ months common at Swiss / Luxembourg counterparts.
The non-dom application was handled end-to-end. I received my certificates within weeks and the tax savings are transformative for my family office.
Olivia B.·United Kingdom·Funds & Family Offices

How it works

Three steps from decision to operational.

1Week 0

Strategy session

We map your global asset base, current residence, family composition, planned home-country exit, fund / family-office target structure. Honest answer on whether Cyprus fits your specific facts. Written plan within 24h.

2Week 1–2

Cyprus entity / fund structure built

Family-office Ltd or RAIF / AIF / AIFLNP entity incorporated. Trust deed drafted if applicable. Investment-management framework documented.

3Week 3–4

Banking + custody

Private banking applications run in parallel. Custodian relationships transferred (UBS, JPMorgan, Citi, Pictet) where you keep them; Cyprus IBAN as the primary collection account for dividends and interest.

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 funds & family offices.

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.

HNWI relocation + non-dom

Pink Slip / Yellow Slip residency, 60-day rule structuring for mobile principals, non-dom certification, year-1 personal tax return locking in 0% SDC on global dividends + interest. Coordination with home-country exit-tax counsel.

From €1,400 (single principal)

Family office Ltd / SoCC structure

Cyprus family-office holding company (Ltd) or single-office consolidated structure. Investment-management agreement, intra-family employment / consultancy agreements, Cyprus International Trust if asset-protection layer is needed.

RAIF / AIF / AIFLNP fund set-up

Selection of vehicle (RAIF for speed / cost, AIF for retail-distribution, AIFLNP for small private capital). CySEC application or notification, AIFM appointment, prospectus drafting, fund administrator + depositary intros.

Cyprus International Trust

CIT settlement deeds, trust-protection clauses, asset-protection structuring against forced-heirship claims, compliance with the 2012 Cyprus International Trust Law as amended. STEP-qualified trustee intros.

Cyprus structuring for funds & family offices, 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

Does Cyprus non-dom apply to fund-distribution / carry income?

Carry / fund-distribution income is taxed based on its character. If structured as a dividend from a fund vehicle, Cyprus non-dom 0% SDC applies. If structured as performance-fee / management-fee income to an individual GP, it's PIT income (taxed at the personal bands). Many family offices and fund GPs structure carry through a Cyprus Ltd to convert to dividend treatment.

Can I keep my UK private bank or do I have to move custody?

Most UK / Swiss / Luxembourg private banks are happy to keep an existing client who relocates. The relationship moves to the bank's non-resident desk, and the tax-reporting changes. The Cyprus side is straightforward additive: open a Cyprus current account for residency / day-to-day, keep your portfolio at the existing custodian.

How does the 60-day rule actually work for someone with houses in 3 countries?

You spend 60+ days in Cyprus, no more than 183 days in any other single country, and you have a Cyprus home (rented or owned) and a Cyprus directorship/business. The 2026 reform repealed the old "not tax resident anywhere else" condition. Treaty tie-breaker applies if another jurisdiction also claims you. We document the calendar, the housing and the directorship in advance to avoid disputes.

What's the realistic cost of running a family-office structure here?

For a single-family office with a Cyprus Ltd, a CIT and basic operations: incorporation €2–€4k; trust deed €4–€10k; ongoing accounting + audit €8–€20k/year; trustee fees €5–€15k/year (depending on AUM and complexity); legal retainer €5–€20k/year. Realistic floor for a properly-built structure: €25–€60k/year all-in, vs €100–€300k+ at Swiss / Luxembourg equivalents.

6 more questions answered on the call. Book a slot →