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If you need practical legal and compliance support for cross-border operations, please get in touch with a brief overview of your business model, the jurisdictions involved, and your key counterparties—such as banks, EMIs, PSPs, or other partners. Based on that information, a proposed scope of work and recommended next steps can be provided.
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Brief us on the objective, jurisdiction and current constraints.
Relocation is a tax event before it is a lifestyle decision
People usually decide to move for reasons that have nothing to do with tax — a family, a business, a passport, a war, a market. The tax and legal consequences arrive anyway, and they arrive in a fixed order: where you cease to be resident, where you become resident, what happens to the assets in between, and what each of the two tax authorities is told.
SK Consult works with founders, executives and private clients on exactly that sequence. Cyprus is frequently the answer, and after the 2026 reform it is a stronger one than it was — but the work is establishing whether it is the right answer for your facts, not selling the destination.
The first substantive conversation is with a senior lawyer. Sergii Kalinovskiy has around twenty years at senior and C-level in law, finance and asset management. Where a mandate requires a licensed firm — an admitted advocate, a statutory auditor, a regulated administrator — that firm is engaged and named. Describe your situation and you will get a straight view of what is realistic.
The numbers that decide most cases
How we approach a personal mandate
Six principles. The order in which they are applied matters more than any single one of them.
Departure before arrival
The country you are leaving usually has stronger claims and a longer memory than the one you are joining. Exit taxes, deemed disposals, continuing residence tests and reporting obligations are established first, because a clean arrival into Cyprus does not repair an unclean departure from somewhere else.
Residency is a test, not a card
A residence permit is not tax residency, and tax residency is not domicile. These are three separate questions with three separate tests, and conflating them is the most common and most expensive error we see in structures built by other advisers.
Presence has to be real and provable
The 60-day route requires business ties, accommodation held for the whole year, and — since the 2026 reform removed the old wording — a residency position that stands on its own terms. Flight records, utility bills and lease agreements are the evidence. Intentions are not.
Personal and corporate are designed together
How you are paid — through salary, dividends or a holding company — changes both your personal rate and the group's effective rate. Advising on one without modelling the other produces a result that is optimal in isolation and wrong in total.
Assume the information is exchanged
CRS, DAC and the register regimes mean that most of what you hold will be visible to the authority that wants to see it. We design structures that read correctly when disclosed, rather than structures that depend on not being read.
Family comes with the file
A spouse's employment, children's schooling, a dependent parent, and where assets sit for succession purposes are part of the plan from the start. Relocations that treat the family as an administrative afterthought are the ones reversed within two years.
Where the work usually sits
Four areas. Most private clients need two or three of them, rarely all four at once.
Cyprus tax residency and non-dom status
The 183-day and 60-day routes, what each actually requires, and which is realistic given how you travel. Non-domiciled status exempts you from SDC on dividends, interest and rents for 17 out of 20 years, and since the 2026 reform it can be extended in five-year blocks at €250,000 per period. Whether that extension is worth taking is an arithmetic question we answer with your numbers, not a matter of opinion.
Relocation and permits
Residence permits, the practical sequence for a family, and how permit categories interact with employment, company ownership and the substance of a Cyprus business. The legal question and the immigration question are usually solved in the same file, because the answers constrain each other.
Personal banking and account opening
Private and personal accounts in Cyprus and elsewhere, prepared the way a compliance officer reads them: a source-of-wealth narrative supported by documents, a coherent explanation of the flows, and an ownership picture that matches the registers. Most personal account refusals are documentation failures, not risk decisions.
Wealth architecture and succession
Holding structures, how assets are owned across jurisdictions, and what happens to them on death or divorce. This is where forced-heirship rules, matrimonial property regimes and the location of the asset matter far more than the headline tax rate, and where decisions taken for tax reasons alone tend to age badly.
What a private client mandate can include
Individual pieces can be taken separately, but they are usually cheaper and safer taken together.
- Tax residency analysis for both the country you are leaving and the country you are entering, with the double tax treaty applied rather than assumed
- Non-domiciled status: eligibility, the 17-of-20 clock, and whether the €250,000 five-year extension is worth taking in your case
- Effective-rate modelling across salary, dividends and holding structures under the 2026 Cyprus personal bands of 0, 20, 25, 30 and 35 per cent
- Residence permits and the practical relocation sequence for a spouse, children and dependants
- Personal and private banking introductions, with the source-of-wealth file prepared before the application rather than after the first question
- Treatment of crypto-assets, including the flat 8 per cent Cyprus rate and how holdings are evidenced and reported
- Holding, succession and asset-protection structures across jurisdictions, including how they interact with forced heirship
- Where privacy is a genuine concern, what a nominee arrangement can and cannot do — a nominee is never the beneficial owner, and the register still receives the real name; see Exclusive Nominee Services
Questions private clients ask first
Will moving to Cyprus actually reduce my tax?
Often, but not automatically and not for every kind of income. The gain usually comes from non-domiciled status removing SDC on dividends, interest and rents, combined with a personal band structure that starts at zero. It can be undone entirely by the country you left continuing to treat you as resident, which is why the departure side is examined first.
How many days do I really have to spend in Cyprus?
The straightforward route is 183 days. The 60-day route exists for people who do not spend 183 days anywhere, and requires business ties, a company role or employment, and accommodation held for the whole year. The 2026 reform removed the old requirement not to be tax resident elsewhere, but the remaining conditions still have to be met and evidenced.
What is the difference between residency and domicile?
Residency determines where you are taxed on worldwide income and is tested annually by days and ties. Domicile in Cyprus is a longer-term concept that determines whether SDC applies, and non-domiciled status runs for 17 of any 20 years. You can be tax resident and non-domiciled at the same time — that combination is exactly what most private clients are seeking.
Can you help with the bank account?
We prepare the file and make the introduction; the bank makes the decision. That distinction matters and we state it plainly. What we can control is that the source-of-wealth narrative is documented, the flows are coherent, and the ownership picture matches the registers — which is where most personal applications actually fail.
Do I have to sell my company before moving?
Usually not, but the timing of any disposal relative to your change of residence can move the tax outcome substantially in either direction. This is one of the few decisions that is genuinely irreversible once taken, so it is modelled before the move rather than explained after it.
Is any of this actually private?
Less than most people expect, and that is the honest answer. Beneficial ownership above 25 per cent is registered, and although public access to the Cyprus register was withdrawn after the Court of Justice judgment of 22 November 2022, the authorities, banks and obliged entities still see it. Anything built on the assumption that nobody will look is fragile.
Where to go next
This page is general information about the services SK Consult provides to private clients. It is not legal, tax or investment advice on your situation and does not create a client relationship. Thresholds, rates and treaty positions change, and outcomes depend on facts specific to you. For a view on your own position, get in touch.
