IPBoxCyprus
Relocation & structuring

How to move your IP & company to Cyprus

Relocating your IP-owning company to Cyprus unlocks the IP Box's ~3% effective rate. It takes careful structuring: establishing Cyprus tax residency and substance, transferring or redomiciling the company, and moving the IP at arm's length. We handle the whole process.

The route

How relocation works

1

Establish Cyprus tax residency

A company is Cyprus tax-resident when its management and control are exercised in Cyprus — a Cyprus-based board taking the real decisions, documented in minutes.

2

Build genuine substance

Real activity in Cyprus: an office, local decision-making, banking and, where warranted, staff. Substance should be planned before, not after.

3

Transfer or redomicile

Either redomicile the existing company to Cyprus (keeping its legal identity) or transfer the IP into a Cyprus company. We pick the cleanest route.

4

Move the IP at arm's length

IP is transferred at a market value supported by transfer-pricing documentation, then the IP Box ruling is secured.

Substance

What real substance looks like

A Cyprus-based board that takes and documents the key decisions.
A genuine office and Cyprus-controlled banking.
Staff or contractors performing real functions in Cyprus.
Records — minutes, contracts, invoices — evidencing local activity.
Moving the IP

Second-hand IP & transfer pricing

IP acquired or moved into Cyprus must be valued at arm's length, with transfer-pricing documentation (a Local File is required once related-party IP transactions exceed €1,000,000; an Advance Pricing Agreement is available). Note that acquisition cost is excluded from qualifying expenditure and lowers the nexus ratio — performing further R&D in Cyprus rebuilds it over time. We quantify this before you commit.

Answers

Relocation FAQ

Get started

Talk to a Cyprus IP Box specialist.

Book a free, no-obligation assessment. We'll confirm whether you qualify, estimate your effective rate, and give you a fixed quote — confidentially, usually within one business day.

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Reviewed by a Cyprus-admitted advocate · Last updated 21 June 2026.

e.g. United Kingdom

Confidential & privileged · Regulated Cyprus law firm. We use your details only to reply — no marketing lists. Privacy