Industry · Software Engineers
Cyprus for senior developers and fractional CTOs — 15% corporate, IP Box on your code
Built for solo engineers, fractional CTOs, OSS maintainers and indie hackers at €120k–€500k/yr. A lean single-founder Cyprus Ltd, the IP Box on owned tools / libraries / dual-licensed OSS, the 50% expat exemption on your own salary, and 0% non-dom on dividends drawn.
The Cyprus stack
Same three layers, applied to software engineers
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 dev profit
~3%
IP Box on qualifying owned code
50%
Off your own salary if eligible
What you save
Worked example: €250k senior developer / fractional CTO, currently a UK Ltd
Senior developer running fractional CTO and high-end consulting at €250,000 revenue, ~€20,000 expenses, €230,000 net profit. Pays themselves €100,000 of dividends per year. Compares a UK Ltd (current) versus Cyprus Ltd with founder relocated as non-dom (with €60k salary using the 50% expat exemption + dividend draw).
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
€59,000+ / year
Over the 17-year non-dom window: ≈ €1m total — before reinvestment compounding and 0% CGT on a future sale.
Today
- Profit before tax (UK Ltd)€230,000
- UK corporation tax (25%)−€57,500
- Net for dividends€172,500
- UK personal tax on €100k dividends (top rate)−€33,750
- Net to engineer€138,750
After Cyprus
- Profit before tax€230,000
- Salary €60k (50% expat exemption, deducted at Ltd)−€60,000
- Cyprus corporate tax (15% × €170k)−€25,500
- Net for dividends€144,500
- PIT on €60k salary (50% exempt; bands on €30k ≈ €2,000)−€2,000
- Cyprus non-dom SDC on €100k dividends€0
- GESY 2.65%−€4,770
- Net to engineer€197,730
Why Cyprus, specifically
Three things Cyprus does for software engineers that nowhere else in the EU does at once.
Tax
15% corporate tax on engineering profit
Legal
Common-law contracts your clients already use
Banking & Ops
Stripe Atlas + GitHub Sponsors + Polar ready
“Transparent pricing was the decisive factor. No hourly billing, no surprises. The quality of the written advice is what you’d expect from a top-tier firm.”
How it works
Three steps from decision to operational.
Strategy call
We map your work mix (consulting / contracting / OSS / SaaS-side / tools), revenue scale, current entity, and target outcome. Honest answer on whether a Cyprus Ltd is right for your scale or if remaining a sole trader is fine. Written scope within 24h.
Cyprus Ltd live
Incorporation in 5–10 business days. Tax & VAT registrations. UBO filed. Banking application started in parallel.
Banking + Stripe + GitHub Sponsors
Cyprus banking opens. Wise Business + Revolut Business as supplemental rails. Stripe Atlas / GitHub Sponsors / Polar / Patreon onboarded as needed.
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 software engineers.
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 engineering Ltd set-up
Lean incorporation tailored for a single-founder developer (or 2-3 person dev team), registered office, beneficial-owner register, tax & VAT registrations. Memorandum & Articles drafted with future-flexibility for adding partners, taking VC investment or selling.
From €1,400 fixed
IP Box mapping for owned code
We map your owned tooling, libraries, OSS dual-licensed offerings and any productised consulting deliverables against the 2026 IP-Box qualifying-asset rules. Nexus-tracking spreadsheet built; qualifying-asset register handed over to your accountant.
Founder relocation + non-dom
Pink Slip / Yellow Slip residency, 60-day rule structuring for travelling devs, non-dom certification, year-1 personal tax return locking in 0% SDC on dividends.
From €1,400
50% expat exemption activation
Compliant employment contract from your Cyprus Ltd to yourself if eligible (over €55k base, not Cyprus tax resident for 15 of the prior 17 years). Year-1 tax filings activate the exemption for 17 years.
Cyprus structuring for software engineers, 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
Is a Cyprus Ltd worth it for a €120k senior dev?
The break-even is typically around €120–€150k of net engineering profit, depending on home country. Below that, simpler arrangements (e.g. continued sole-trader status with personal Cyprus residency only) often win because the Ltd running cost (€7–€10k/yr) eats a meaningful share of the saving. We're honest on the first call — if it's not worth it, we say so.
What about my reusable tooling / libraries — does the Ltd own them?
Yes — reusable tooling, libraries and frameworks are assigned to the Cyprus Ltd via written deeds. We draft the assignment carefully so pre-existing IP transfers cleanly, and we update your standard MSAs with reusable-IP carve-outs so future client work doesn't sweep your reusable building blocks into client ownership.
Does the IP Box apply to consulting deliverables?
Pure consulting (time-and-materials, work-for-hire deliverables) is service revenue, not IP licensing — taxed at the headline 15%. What can qualify is licensing of your owned tools / libraries / OSS dual-licensed offerings. Many engineer P&Ls have a 20–40% IP-licensable portion (productised tools, dual-licensed OSS, retained framework code) which gets the ~3% effective treatment.
Can I keep contributing to OSS as a Cyprus Ltd founder?
Yes. We draft a clean OSS-contribution policy distinguishing your personal contributions (under your personal GitHub identity, on your own time) from company-owned releases (under the Cyprus Ltd's GitHub Org). Dual-licensed OSS offerings owned by the Ltd can also be IP-Box-qualifying assets.
6 more questions answered on the call. Book a slot →
Keep reading
Deeper guides for software engineers
- Cyprus for freelancers & solo foundersWhen sole-trader vs Cyprus Ltd makes sense, the break-even economics, and the 50% expat exemption.→
- The Cyprus IP Box, plain EnglishWhat qualifies (yes, software and OSS dual-licensed offerings can), how the 80% deduction works.→
- The 50% expat salary exemptionHow to apply it to your own salary as a developer, and the eligibility tests in 2026.→
- Non-dom status explained simplyThe 17-year window of 0% on dividends — what it is, who qualifies, what changed in 2026.→
Also serving: SaaS Founders · Consultants & Freelancers
Page last reviewed April 2026. Estimates only — not legal, tax or financial advice.