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Art. 30da exit tax playbook

Poland taxes unrealised gains above PLN 4 million. Cyprus taxes dividends at zero.

Poland stacks a 32% income tax, a 4% solidarity levy above PLN 1m, a flat 19% on dividends and investment gains, and an exit tax on unrealised gains above PLN 4m. Cyprus offers a 60-day residency rule and zero tax on dividends for non-doms.

PLN 4m

Polish exit-tax trigger

36%

PIT 32 + 4% solidarity top

15%

Cyprus CIT from 2026

0%

Cyprus SDC dividends

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Step 1 · Poland today

What you actually pay living in Poland

Here’s the headline tax burden a Polish founderfaces in 2026 — income tax, tax on dividends and investment income, wealth or property-style taxes, and anything due on the way out. Regional and social-security add-ons are included where they materially change the number.

Personal income tax bands12% up to PLN 120,000 (~€28k); 32% above
Solidarity levyExtra 4% on income above PLN 1,000,000 (~€230k) — takes the top to 36%
Tax on dividends, capital gains and interest19% flat on all investment income
Corporate tax19% standard; 9% for small taxpayers (revenue up to €2m); Estonian-style deferred CIT available
IP Box5% effective on qualifying IP income
Exit tax19% on unrealised gains on holdings above PLN 4m; triggers for 5-of-10-year residents; EU move gets deferral
Return reliefFour tax-free years up to PLN 85,528/yr for returnees (3+ years non-resident)
Inheritance and gift tax3-20% by relationship group; close family exempt if reported within 6 months

Step 2 · Side by side

Poland vs Cyprus, line by line

Tap any row for the full “why this matters” explanation. The two columns are the two sides of the decision — what you pay today versus what you’d pay with Cyprus non-dom.

What matters
Poland
Cyprus

Interactive · 30-second estimate

See what a move to Cyprus is worth for you

Enter your annual distributed dividend income below. The calculator shows what you’d pay today in Polandversus what you’d pay as a Cyprus non-dom, with a live side-by-side.

Assumes the full amount is distributed as dividends (or equivalent investment income) and the Poland flat tax on investments of 19% applies. Cyprus side assumes non-dom status plus the capped 2.65% health contribution. Real numbers depend on your full picture — we confirm on a free call.

Poland today

Tax paid

€47,500

You keep

€202,500

Cyprus non-dom

Tax paid

€4,770

You keep

€245,230

Your estimated saving

€42,730/ year

Over the 17-year Cyprus non-dom window: €726,410

17.1% of income back

Step 3 · Why the move

The structural issues driving Polish founders out in 2026

The 4% solidarity levy on everything above PLN 1m

Employment, business and capital-gains income above PLN 1,000,000 (~€230,000) picks up an extra 4%. Stacked with 32% income tax, your top earned-income rate is 36%. Stacked with the 19% investment tax, the top on investment income is 23%. Cyprus has no equivalent surcharge — 35% top on salary, 0% on dividends for non-doms.

19% flat tax on dividends, interest and gains

Poland taxes dividends, bank interest, bond yields, fund gains and crypto at a flat 19% with no personal participation exemption. A Cyprus non-dom pays 0% on dividends and interest for 17 years. On €500k of annual investment income the gap is roughly €82k a year.

Exit tax on unrealised gains above PLN 4m

If you have been Polish-resident for 5 of the last 10 years and your private holdings are worth more than PLN 4,000,000 (~€920k), you owe 19% on unrealised gains on the way out. Moves inside the EU get a deferral of up to 5 years, with the tax only falling due on an actual sale. Cyprus qualifies.

Step 4 · The Cyprus answer

Cyprus in one screen

The simplest founder tax position in the EU after the 2026 reform: low corporate rate, zero tax on dividends for non-doms for 17 years, no wealth tax, no inheritance tax. Six numbers tell most of the story.

Corporate income tax

15%

Flat; IP Box effective ≈3%

SDC on dividends (non-dom)

0%

For 17 years

Top personal tax

35%

First €22,000 at 0%

CGT on non-RE shares

0%

Only Cyprus real-estate shares are taxed

Wealth / net worth tax

None

No annual wealth levy

Inheritance / gift tax

None

Abolished decades ago; not coming back

Step 5 · Life in Cyprus

Beyond the tax math — why founders actually stay

Tax moves people in. Life keeps them here. Nine practical reasons families settle, beyond what the spreadsheet says.

Climate

340+ sunny days — #1 climate globally

More than 340 sunny days a year. Winter lows rarely below 13–15°C on the coast; sea swimmable April–November. WhereNext ranks Cyprus #1 for climate in 2026.

Safety

Among the 15 safest countries in the world

Ranked 13th globally by Global Finance 2026. Homicide rate 0.4–0.8 per 100,000. Low violent-crime environment — families notice within weeks.

Language

English + common-law legal system

English is the default business language; courts and contracts run in English. The legal system is inherited from the UK — familiar for founders from UK, US, Ireland and the Commonwealth.

Healthcare

Universal GESY since 2019 + strong private

Public healthcare covers everyone at ~2.65% of income. Cyprus has one of the EU's lowest death-rates from preventable causes. Private insurance adds €150–€300/adult/month — half of Western Europe.

Schools

British, American and IB schools across the island

British curriculum (IGCSE, A-Levels), American, and International Baccalaureate options across Nicosia, Limassol, Larnaca and Paphos — with long waitlists filled by children of relocating founders.

Connectivity

Two airports, Europe and Gulf in 4 hours

Direct flights from Larnaca and Paphos to London, Paris, Frankfurt, Athens, Dubai, Tel Aviv, Milan and Barcelona. Most of Europe, the Gulf and the Levant inside a 4-hour flight radius.

Step 6 · Your right to live in Cyprus

As an EU citizen you don't need permission. You just register.

Your right to live in Cyprus comes from being an EU citizen. The paperwork simply records that — it doesn't grant anything. Two stages: the Yellow Slip on arrival, upgraded to permanent residence after five years.

Yellow Slip

Your EU registration certificate

Filed once you’ve moved, within four months of arrival. Cheap, fast, and valid for life. You show what you’ll be doing in Cyprus (working, running a business, living off income, or joining a spouse) and that’s it.

Deadline

4 months after you arrive

Processing

About a month

Validity

Indefinite

Read the full Yellow Slip guide →

After 5 years

Permanent residence, automatically

Stay five years and your registration upgrades to unconditional permanent residence. Short trips don’t interrupt the clock, and your right can’t be lost unless you leave Cyprus for more than two years straight.

Step 7 · Becoming a Cyprus tax resident

Two ways in: 183 days, or just 60

Cyprus lets you become tax resident either by being here most of the year, or — if you’re mobile — by spending as little as 60 days a year here and meeting a few extra conditions. The second route is the one mobile founders use.

183

The 183-day rule

Spend more than 183 days of the calendar year in Cyprus and you’re a Cyprus tax resident — full stop, no other conditions. The day you arrive counts, the day you leave doesn’t. This is for people who genuinely live here most of the year.

60

The 60-day rule

All three of these need to be true in the same year (the 2026 reform removed the older fourth condition):

  1. 1You spend at least 60 days in Cyprus
  2. 2You don't spend more than 183 days in any other single country
  3. 3You have a home in Cyprus (owned or rented) and you run a business, work or hold a directorship here — kept active through the end of the year

In plain English: a Cyprus home, a Cyprus company or role, and 60+ days a year on the island. Dual-residency conflicts are now resolved through the tax treaty with your other country rather than by a blanket "not resident elsewhere" test. How the 60-day rule works in practice →

Step 8 · Non-dom status

17 years of 0% tax on your dividends, interest and rent

Cyprus keeps a simple promise for newcomers: as long as you’re not domiciled here, worldwide dividends, interest and rental income skip the defence contribution that Cypriots pay. That’s a 17-year window where your investment income effectively sees a 0% line on the Cyprus side.

Dividends

Domiciled: 5% + small health levy

Non-dom: 0% + small health levy

Interest

Domiciled: 17% + small health levy

Non-dom: 0% + small health levy

Rental income

Domiciled: Progressive income tax

Non-dom: Progressive income tax

How long does non-dom last?

You get 17 years of non-dom status as standard. Under the 2026 reform, two additional 5-year extensions are available at €250,000 each, taking the window up to 27 years in total. Deemed-domiciled residents can instead elect a flat €50,000/year contribution for 5 years in lieu of the variable defence contribution. Enacted and in force. Non-dom, plain English → · What happens after year 17 →

Step 9 · Leaving Poland

Leaving Poland cleanly

Moving to Cyprus only works if Polandstops claiming you for tax at the same time. The steps below are the ones that actually matter — the rest is paperwork your lawyer handles.

  1. 1

    Break your Polish tax residency

    Poland treats you as resident if your centre of life (family and economic ties) is in Poland, or if you spend more than 183 days there in a calendar year. The centre-of-life test usually bites first — a Polish family home or business anchor keeps you in the net. Move the whole household and put the paper trail in Cyprus: lease, utilities, schools, doctors.

  2. 2

    Work through the exit tax

    If you have been resident 5 of the last 10 years and your private holdings exceed PLN 4m, Poland wants 19% of the unrealised gain at departure. An EU move like Cyprus gets up to a 5-year deferral, with tax only due on an actual disposal — so plan on the assumption the rule applies and use the deferral. If you are mid-way through return relief, that relief ends the day you leave, so the window is a timing call.

  3. 3

    Decide what happens to your Polish company

    A Polish Sp. z o.o. or SA stays Polish-resident for corporate tax wherever you live. The usual options are: keep it and pay dividends out to Cyprus; put a Cyprus holding over it; redomicile under EU cross-border mobility rules; or wind it down. On dividends out, the Poland-Cyprus treaty caps withholding at 5% for a corporate shareholder holding at least 10% (10% otherwise); the EU parent-subsidiary rules can take that to 0% where a Cyprus parent with real substance holds at least 10% for 24 months.

  4. 4

    Special case: Estonian-style deferred CIT

    A Sp. z o.o. under Poland's Estonian-style deferred CIT regime has to stay Polish-resident to keep the regime. You can personally relocate to Cyprus and leave the company under that regime — distributions then flow through normal treaty and EU rules to your Cyprus non-dom position.

Step 10 · Your relocation, month by month

From decision to non-dom, in five stages

The whole thing is usually a three-to-four month project for the paperwork, plus the time it takes you to physically relocate. See the relocation package →

  1. 1

    Before you move

    Get the exit side right

    The biggest relocation mistakes happen at home, not in Cyprus. Confirm when your home-country tax residency actually ends, sort out any exit-tax exposure on company shares, and decide what happens to any existing business. This is where most of the money is made or lost.

  2. 2

    Month 1

    Set up the Cyprus side

    If you plan to use the 60-day rule, you need a Cyprus company and a role in it. We handle the incorporation, registered office and tax registrations so it's ready before you arrive. About 5–10 business days.

  3. 3

    Month 2

    Move and file your Yellow Slip

    You arrive, rent or buy a home, and file the Yellow Slip within four months. It's inexpensive, quick, and confirms your right to be here on paper.

  4. 4

    Month 2 onwards

    Build up your Cyprus days

    Whichever route you use — 60 days with ties, or 183 days — the important thing is to track presence properly from day one. A simple log, boarding passes, and receipts are enough. We tell you when you've crossed the line.

  5. 5

    Year 1

    First Cyprus tax return, non-dom locked in

    At the end of your first tax year we file the return that formally registers you as a Cyprus tax resident and non-dom. From that point forward, your dividends come to Cyprus on the 0% line for the next 17 years.

Step 11 · What it’s worth

Worked example: a Polish founder with €500k dividend income

A Warsaw founder owns 100% of a Polish Sp. z o.o. that distributes around €500k (~PLN 2.17m) a year, compared against the same founder after a clean move to Cyprus on non-dom status.

Today, in Poland

  • Sp. z o.o. profit€617,000
  • CIT (19%)€117,230
  • Distributable€499,770
  • 19% flat tax on dividend€94,956
  • Solidarity levy 4% on top bracket≈ €11,000
  • Take-home≈ €393,814
Cyprus

After the move

  • Cyprus Ltd profit€617,000
  • Cyprus CIT (15%)€92,550
  • Distributable€524,450
  • Non-dom tax on dividend€0
  • Health contribution (capped)~€4,770
  • Take-home≈ €519,680

Annual net saving

≈ €126,000 per year

Over the 17-year non-dom window: ≈ €2.14m over the 17-year non-dom window

Free consultation

See your Poland → Cyprus savings in writing

A 30-minute call with a licensed Cyprus lawyer, followed by a written scope of work and fixed-fee quote within 24 hours.

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Step 12 · Common questions

FAQs from Polish founders

Can I keep the Estonian-style deferred corporate regime and still move to Cyprus?
Yes. That regime sits at the company level — it only works if the Polish company stays Polish-resident. You can personally move to Cyprus while the company stays under the deferred regime. Distributions to you then flow through the normal treaty and EU rules, and land on your Cyprus non-dom position at 0%. It's a legitimate hybrid for certain business types.
How much does the 4% solidarity levy cost me?
Take a Polish resident on around €690,000 of dividend income a year. They pay 19% flat tax on the lot — €131,000 — plus 4% solidarity on everything above roughly €230,000 — another €18,400. Combined tax on those dividends: about €149,000. Cyprus non-dom with the same income: 0% plus the capped health levy of about €4,770. Annual saving: around €145,000.
Will the exit tax definitely catch me?
Only if your private holdings are worth more than PLN 4m at the point of departure and you've been Polish-resident for 5 of the last 10 years. If both are true, yes — but the EU deferral to Cyprus is automatic, and the tax only becomes payable on an actual sale within the deferral period. Plan around it, don't panic about it.
Do I need a visa for Cyprus?
No. As an EU citizen you move freely. Within four months of arriving you register with a Yellow Slip — inexpensive, valid for life.
Does the Polish IP Box travel with me?
No. The Polish IP Box only applies to income taxed in Poland. Moving to Cyprus takes you out of Polish personal tax except on Polish-source income, and out of the Polish IP Box. Cyprus has its own IP Box at about 3% effective on qualifying IP income, which can apply if the IP sits in a Cyprus-resident company with real substance. Moving the IP over is a planning exercise in itself — we'd scope it properly before you commit.
How long does a Poland-to-Cyprus move take?
Usually 3 to 4 months. A couple of weeks for the Cyprus company and tax residence, a few weeks for the Yellow Slip, and the Polish side running in parallel. If you own a company with intellectual property or you're on the deferred corporate regime, add a month or two for the corporate planning.

Find your fit

Which relocation package fits your Poland move?

Four quick questions — we’ll tell you which package fits and why, so your free consultation starts from a concrete plan instead of a blank page.

Package Finder

Answer 4 quick questions

Non-EU vs EU citizenship, days in Cyprus, Cyprus company needed, family composition — the same checks a lawyer would run on a first call.

Official references

Page last reviewed April 2026. Estimates only — not legal, tax or financial advice. No solicitor-client relationship is created by reading it. Book a free consultation for written advice on your situation.

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