Create a company in Cyprus — or move your company from Austria

Austria does tax you for leaving, and it usually takes no cash at all. Moving from Austria to Cyprus triggers a deemed realisation of your shareholding under § 27 Abs. 6 EStG — but for a departure into another EU state the liability is assessed and then simply not levied, on application. The application, not the tax, is the thing that decides your outcome.

Updated for 2026 Cyprus tax law and regulations.

One note on sourcing before any figure, because it changes how you should read the Austrian half of this page. The Rechtsinformationssystem des Bundes was returning HTTP 503 for every request throughout the research behind this guide, so no Austrian statute was read in its own text. Everything Austrian below is cited to the Finance Ministry's own Erlässe and information pages or to the federal business service portal — official, but administrative guidance rather than the law itself. Where that leaves something unconfirmed, we say so on the line and print no number.

One partner for the Cyprus half of an Austrian move

Sumly is the fully digitalized way to start a company in Cyprus, bring an Austrian business across, and run it from the first day it exists. We register the company, open your books the day you order, prepare every Cyprus return field by field, and deliver the Yellow Slip, tax residency and non-dom registration as fixed-price services. One dashboard, one provider, prices visible before you order — instead of a Steuerberater on one side, a Cyprus lawyer on the other, and nobody at all holding the middle.

This is Sumly — and what we actually do for you

Sumly is the fully digital provider for founders moving a company to Cyprus. You do not need to learn Cypriot company law, find a local auditor, or work out which form goes where. You get in touch, and we do the rest.

And we stay with you on both sides of the move. The Cyprus side we own outright. For the side you are leaving, we put you straight in front of an adviser or lawyer from our network who works on exactly your problem — company law, exit taxation, inheritance, employment — and we hold the thread between them and us. One point of contact for the whole move, however many specialisms your case turns out to touch. If your case is simple, we do all of it for a fixed price.

Part 1: What leaving actually costs you

Your home country does not let go the moment the plane does. What still runs after you have left, and in which order it has to be handled.

Does Austria charge an exit tax when you leave for Cyprus?

Yes, and it is broader than most Austrian founders expect, because it does not wait for you to do anything. § 27 Abs. 6 EStG attaches to circumstances in which Austria's right to tax an asset is restricted, and the Finance Ministry states plainly in its maintenance decree to the income tax guidelines that an active act by the taxpayer is not required. The triggers it names include moving abroad, transferring an asset to another person without consideration, the taxpayer's death, and the conclusion or amendment of a double tax treaty.

The one that catches careful people is subtler. Keeping the Austrian dwelling and staying unlimitedly liable does not switch the charge off: the same decree records that the liability arises even where the domestic residence is retained, if the centre of vital interests moves abroad and the treaty hands the exclusive claim on later appreciation to the other state. In other words, you can remain an Austrian taxpayer in every formal sense and still have crystallised a deemed disposal.

Scope matters too, and it runs against intuition. Holdings in Austrian companies are caught on a move out only where Austria's taxing right is genuinely restricted. Holdings in foreign companies are always caught, because limited liability does not reach them at all. A founder whose operating company already sits outside Austria is therefore more exposed on the way out, not less — which is worth knowing before anyone restructures in the wrong order.

Was the Nichtfestsetzung really abolished for Austrian founders?

No — and this is the correction that most of the published German-language advice gets backwards. The Nichtfestsetzung concept was replaced by an instalment regime in the business-asset rules of § 6 Z 6 EStG, not in the private capital-asset rules that govern a founder's own shares.

The decree sets out the business-asset history precisely: the Nichtfestsetzung concept previously available under § 6 Z 6 towards EU and EEA states with comprehensive administrative and enforcement assistance was replaced by an instalment concept by the AbgÄG 2015, for transfers from 1 January 2016. The JStG 2018 then aligned that regime with Article 5 of the ATAD by shortening the instalment period for fixed assets from seven years to five, applying to restrictions from 1 January 2019, with two years for current assets. Departures before 2016 keep the old regime, and the exit of a state from the EU or EEA does not by itself crystallise anything.

For private capital assets the rule is different in kind. Where a natural person moves to an EU or EEA state with comprehensive mutual assistance, the decree provides that the liability arising on departure is, on application, not to be assessed for collection until the actual disposal of the holding. The same applies to a gratuitous transfer of an asset to another natural person resident in such a state. The instalment route reaches § 27 cases only where lit. a does not apply — a contribution of shares into a foreign corporation or private foundation, for instance, which is neither a move nor a gift to an individual.

Is that still the position in 2026? Yes. The Ministry's 2026 maintenance decree amends the relevant paragraph and works the concept through with fresh examples, including a taxpayer moving to Budapest and another moving to Munich and then onward, where a further move inside the EEA changes nothing and a move to a third country produces a deemed sale. A concept the tax administration is still maintaining and re-illustrating in a 2026 decree is a live concept.

So the honest headline for an Austrian founder relocating to Cyprus is not five instalments. Cyprus is an EU Member State with comprehensive mutual assistance, and the correct answer is deferral until you actually sell, with nothing payable on departure — provided the application is made.

How do Austrian founders lose the deferral?

By missing a deadline they never knew existed. There are three failure modes, and the first is fatal.

The second failure mode is that later events reach back. A real disposal after the move, or an onward move or transfer of the asset to a third country, is a retroactive event under § 295a BAO, and it amends the assessment for the departure year rather than being taxed in the year it happens. You also have to tell the tax office yourself: the 2026 draft records the taxpayer's duty under § 120 Abs. 3 BAO to notify the competent tax office when the retroactive event occurs. The draft is also precise about what counts as a realisation: a post-departure transaction that is either not tax-neutral under the foreign law or could not be tax-neutral under Austrian law.

The third is that a gift does not clean the slate. The Ministry's own worked example has a taxpayer gifting shares to his son in Munich and applying for Nichtfestsetzung; when the son sells the following year, that sale is the retroactive event, and it amends the father's departure-year assessment. Handing the asset on does not hand on the exposure.

The practical consequence deserves stating plainly, because no competing page states it: your Austrian file does not close when you land in Larnaca. It stays open for as long as you hold the asset, with a self-reporting duty attached, and an onward move to a non-EU jurisdiction years later crystallises everything at once.

When does Austrian tax residency actually end?

Later than the paperwork suggests, and it does not end at the Meldeamt. Unlimited liability under § 26 BAO rests on two independent tests, and either one is enough.

A Wohnsitz exists where you have a dwelling at your disposal that you evidently use as such over a longer period — and the Ministry is explicit that it need not be your main residence and only has to be suitable for living given your circumstances. There is no minimum day count in that test at all. A gewöhnlicher Aufenthalt exists where you are present not merely temporarily but evidently for a longer time, and here there is a hard rule: after six months of presence in Austria, unlimited tax liability arises retroactively, back to the beginning of the stay. Unlimited liability means worldwide income.

Now the myth. Deregistering from the Zentrales Melderegister is an act under civil registration law. It is not the § 26 BAO test, it does not create the tax outcome, and it does not prevent it. The most on-topic English page currently ranking on this query treats the Abmeldung as a tax step; it is not one. Deregistration follows the facts. It never manufactures them.

What happens if you keep the flat in Vienna?

This is the provision that decides whether an Austrian founder who moves to Cyprus and keeps a property at home stays inside the Austrian net, and it is almost entirely absent from the competing coverage.

The Zweitwohnsitzverordnung sets the conditions on which holding an Austrian second dwelling does not produce unlimited liability. The Ministry's own statement of it requires that the centre of vital interests lie abroad for at least five calendar years, and that a register kept in list form proves the Austrian dwelling is used for no more than 70 days per calendar year. Three conditions, all of which have to hold at once: five years abroad, seventy days, and the register itself.

The timing is better than people assume. Where the main residence moves abroad and the Austrian dwelling is used only for holidays within that limit, the switch to limited liability takes effect from the beginning of the calendar year following the move of the main residence, and not only after the five years have run. You do not wait out a five-year probation before the relief starts.

The register is a condition of the relief in its own right, not an evidential nicety, so keep it contemporaneously and day by day rather than reconstructing it later. We have seen it asserted that failing to keep the register defeats the relief on its own regardless of the true day count; that proposition rests on case law we did not read for this guide, so we do not state it as settled. Treat the register as mandatory anyway, because the Ministry's text makes it a condition.

Where is your Cyprus company actually managed?

Wherever the decisions are made, which is a question about your calendar rather than your certificate of incorporation. Under Austrian corporate residence rules, corporations with their place of management or their registered seat in Austria are subject to unlimited corporate tax liability — either limb is sufficient — and the place of management is the centre of the commercial top-level direction, where the decisive managing will is formed and the important business-directing decisions are taken. It need not coincide with the seat.

The consequence is short and worth repeating to anyone selling you an offshore structure: registering a company in Nicosia does not move its tax residence if you keep directing it from Vienna. Austria will assert unlimited liability on the place of management alone, and the Cyprus registration is simply not part of that test. This is the substance requirement expressed in Austrian terms — real decisions taken in Cyprus, minuted in Cyprus, by people who are actually there.

Do Austrian CFC rules catch a Cyprus company in 2026?

They can, and the answer changed at the turn of the year. § 10a KStG turns on whether a foreign corporation is low-taxed, and the Ministry confirms that the concept of low taxation now refers uniformly to a tax rate of 15%, by an instrument published on 29 December 2025 after a third reading in the Nationalrat on 10 December and unanimous passage in the Bundesrat on 18 December.

That is a bigger deal for a Cyprus page than it looks. The previous formulation in the corporate tax guidelines defined low taxation as an actual burden on total income abroad of not more than 12.5% — at the line, not merely below it. On the same not-more-than shape, a Cyprus company paying the standard corporate rate of 15% from tax year 2026 sits exactly on the threshold rather than safely above it. And because the test measures the effective average burden — the foreign taxes actually paid divided by the foreign income, not the headline rate — any narrowing of the Cyprus base pulls a company under the line even when its nominal rate does not.

We are not going to print the other two limbs of § 10a as numbers. A control test and a passive-income test sit alongside the low-tax test, and neither could be verified against an official source in this research pass, because the implementing regulation lives only on RIS. Treat them as real conditions with thresholds you should get from your Steuerberater rather than from this page.

What being caught costs comes in two shapes, and the difference matters. Hinzurechnungsbesteuerung taxes the passive income of a low-taxed controlled foreign corporation directly at the Austrian controlling corporation, already on undistributed profits — there is no waiting for a dividend. The Methodenwechsel applies to portfolio holdings instead, switching the participation exemption off so dividends become taxable with a credit for the foreign tax. And where intercompany terms are not at arm's length, transfer-pricing corrections rank ahead of the CFC charge: the pricing gets fixed first, and CFC then applies to what is left.

The fork that actually decides your case is simpler than the mechanics. § 10a is a corporate provision. It bites where an Austrian company controls the Cyprus company. A founder who genuinely relocates and holds the Cyprus shares personally is outside § 10a altogether; the exposure is then § 27 Abs. 6 on the way out, and Cyprus's own rules once you arrive. Getting that fork right is worth more to you than any rate on this page.

Should you claim the Cyprus IP Box if you keep an Austrian holding?

Not unconditionally, and this is where a page that just sells the IP Box would do you harm. Qualifying income under the Cyprus regime is taxed at 3% from tax year 2026. Set that against an Austrian low-tax threshold that is now 15% and the arithmetic is uncomfortable: an effective 3% is unambiguously under the line. If an Austrian corporation sits above your Cyprus company, the IP Box is exactly the thing that makes the Cyprus company low-taxed for § 10a purposes, and the saving you claimed downstairs can reappear upstairs as a Hinzurechnung on undistributed profit.

That is not an argument against the IP Box. It is an argument for deciding the ownership structure and the IP Box question in the same conversation rather than in sequence. For a founder who has moved personally and holds the shares as an individual, the § 10a problem does not arise and the regime is simply the largest line in the position. The IP Box is the largest single line in a Cyprus product company's tax position — and the easiest one to forfeit through bookkeeping that was never set up for it. The application starts as a conversation, and the mechanics are on the IP Box service page.

What does an Austrian founder actually pay today?

More than the corporate rate suggests, and the government publishes the honest number itself. Austrian corporate tax is 23%, flat, down from 25% until 2022 and 24% in 2023. That is not the burden on money you take out.

Distributions to an individual shareholder carry Kapitalertragsteuer at 27.5%, and the business service portal works the combination through on its own example: a distributing GmbH produces a total tax burden of 44.18%. Use that figure, not 23%, whenever you compare Austria with anywhere else — comparing a foreign combined burden against Austria's corporate layer alone compares the wrong things.

The same 27.5% reaches gains as well as dividends. The Ministry confirms it applies to realised increases in value covering shares, GmbH interests, debt securities, investment fund units and property fund units for securities acquired after 1 January 2011, levied as a withholding with final effect. Flat, final, no progression — and, said plainly, a decent regime by European standards for someone whose income is mostly investment return.

There is also a charge that survives a loss year. Unlimited-liability corporations pay a minimum corporate tax computed as five percent of a quarter of the statutory minimum share capital for each full calendar quarter, regardless of profit. We give the formula rather than a euro figure, because the minimum share capital it multiplies was not separately verified in this research pass.

A Cyprus non-dom keeps that dividend position for 17 years, and the health contribution runs at 2.65% on income up to €180,000 a year. A domiciled Cyprus shareholder instead pays 5% on dividends from 2026 profits, which is why the non-dom registration is not an optional extra on this route.

Does Austria tax your wealth, your estate or your gifts?

No, on all three, and this is where Austria genuinely competes. The Finance Ministry's own index of current Austrian taxes lists income tax, corporate tax, KESt, ImmoESt, wage tax, VAT, Grunderwerbsteuer, Grundsteuer, Kommunalsteuer and the excise duties — and contains no Vermögensteuer, no Erbschaftssteuer and no Schenkungssteuer. Austria has levied no net wealth tax since the mid-1990s; the exact effective year is disputed between sources and we do not print one, because we could not confirm it officially.

Inheritance and gift tax lapsed after the Constitutional Court struck down the valuation base, and the legislature let the charging provisions expire rather than repair them. What it enacted instead was the Schenkungsmeldegesetz 2008, BGBl. I Nr. 85/2008, passed by the Nationalrat on 6 June 2008 and the Bundesrat on 19 June 2008. Austria abolished the tax and kept the paperwork.

What Austrian founders get wrong before gifting shares to family

The Schenkungsmeldung is the best example on this page of something expensive that almost nobody writes about in English, and it lands precisely where a relocating founder tends to act — moving value to a spouse or children before or during the move.

Look at what the reporting duty covers. The Ministry's list includes cash, capital claims, shares in corporations and partnerships, silent participations, businesses and parts of businesses, movable tangible property and intangible assets. Company shares and whole or partial businesses: exactly the assets a founder transfers when doing succession planning around a relocation.

The thresholds are rolling, and lower than people expect. Transfers between relatives are exempt up to a fair value of €50,000 within one year; between other people the exemption is €15,000 within five years. Above that, the report must be filed within three months of the acquisition, through FinanzOnline on form Schenk 1 or on paper. Missing it carries a fine of up to ten percent of the fair value of the gifted assets.

And the duty is not somebody else's job. It falls jointly and severally on the donee, the donor, and any lawyer or notary involved — so there is no defence that the other side would have filed it. Ten percent of a company stake, for a purely administrative failure, on a gift that costs nothing in tax: that is a bad way to start a new life.

There is one more interaction to hold in your head, because the two provisions fire together. A gratuitous transfer of shares to an individual resident abroad is itself a trigger under § 27 Abs. 6. So the same gift raises both a Wegzugsbesteuerung question and a Schenkungsmeldung deadline, on two different clocks, with two different penalties. Handle them in the same sitting.

Does Austrian property follow you to Cyprus?

The property does, and so does the tax on transferring it. Grunderwerbsteuer is generally calculated at a rate of 3.5%, with a graduated tariff for gratuitous acquisitions and transfers within the family: 0.5% on the first €250,000, 2% on the next €150,000 and 3.5% above €400,000 of the property value.

The point for a departing founder is that the charge attaches to Austrian land, not to the owner's residence. Leaving does not shed it. More usefully, it can be triggered by share transactions in a company holding Austrian property — changes in the partner circle, consolidation of interests, reorganisations — so restructuring into a Cyprus holding while keeping an Austrian property company can produce a Grunderwerbsteuer event without a single square metre changing hands. Nobody writes about this in a relocation context, and it is a real line item.

Does the Austria–Cyprus treaty settle anything?

It settles the tie-breaks, which is precisely what makes the exit charge fire. Cyprus appears on the Ministry's official list of Austrian double taxation agreements, and the agreement is an income and capital convention — a relic of the era when Austria still levied a tax on capital, with a later protocol concluded.

We are not printing its official gazette reference. Two mutually inconsistent numbers surfaced in the research, the Ministry's own list page truncated, and the statute database was unreachable, so the only safe statement is that a comprehensive income-and-capital treaty is in force. What matters practically is what it does: it decides which state wins when both assert residence, and it hands Cyprus the taxing right over appreciation after you arrive — which is exactly why § 27 Abs. 6 fires on the way out. Note also the trigger from the section above: the conclusion or amendment of a treaty is itself an Entstrickung event, so a future protocol could crystallise something with no action by you at all.

What about SVS, ASVG and your Austrian pension?

We did not research this, and we are going to say that instead of guessing. The treatment of self-employed social insurance with the SVS, of ASVG and GSVG entitlements, and of Austrian pension rights on a move into another EU state is coordinated at EU level and is not a tax question — but it is, for many Austrian founders, financially at least as significant as everything above. It sat outside the work behind this guide, so there are no numbers here and there should not be. Get Austrian advice on it specifically, and get it before the departure-year return is filed rather than after.

Everything else on this page is sourced. This is a deliberate gap rather than an assumption, and we would rather show you the edge of our research than dress it up.

Part 2: What Cyprus gives you

This is the straightforward half, and the half we build end to end. What you actually get on the other side.

How does an Austrian founder become Cyprus tax resident?

Usually through the 60-day rule, which became easier in 2026. The route everyone knows is 183 days a year on the island. The 60-day alternative trades days for genuine commitment on the ground, and for a founder who still has Austrian clients or an Austrian company that is normally the better trade.

From tax year 2026 the rule has four conditions, after a fifth was removed from the 60-day rule: at least 60 days in Cyprus; no more than 183 days in any other single state; a business, employment or office in a Cyprus tax-resident person held throughout the year; and a permanent home in Cyprus you own or rent. The condition that fell away was not being tax resident anywhere else — awkward for mobile founders, because another state's claim used to disqualify you outright. Competing claims now resolve under the treaty instead.

Two Austrian specifics. First, a directorship of your own Cyprus company can be the office the third condition asks for, so the formation and the residency are one project rather than two — and a directorship that is genuinely exercised in Cyprus is also the evidence that answers the place-of-management test above. Second, as an Austrian citizen you are an EU citizen, so the Yellow Slip is open to you: the registration certificate that formalises residence in Cyprus under EU free movement. It is a residence registration, not a tax status — our guide explains the difference, and Sumly handles the application. Tax residency and non-dom are the separate step at €750 per person through the tax residency service, and the 60-day rule guide covers the day counting properly.

Personal income tax in Cyprus runs from 0% to €22,000 rising to 35% above €72,000, VAT registration bites at €15,600 of taxable turnover, and the standard VAT rate is 19%. Neither a net wealth tax nor an inheritance tax exists in Cyprus at all.

Why do people choose Cyprus over other tax havens?

Because Cyprus is somewhere you would choose to spend a decade, and most of the alternatives are somewhere you would endure one. The tax is what makes an Austrian founder look; it is almost never what makes them stay.

Violent crime in Cyprus sits at the low end of anything measured across the European Union. It is an English-speaking country in every way that matters to a business — banking, professional services, contracts and most of the administration run in English, which for an Austrian founder is a smaller adjustment than it sounds and a larger one than moving to Sofia or Athens. People from all over the world are already here, so nobody ends up the only foreigner in the room. Business and real estate are booming, and the state stays friendly and open towards people who want to trade, without wrapping it in heavy regulation. Groceries — meat, fruit, vegetables — cost noticeably less than in Vienna or Salzburg. And the coast: a Cyprus winter still allows a swim, while the summers are the reason people book flights from the other side of the planet.

The honest Austrian push list is shorter than a marketing page would like, because Austria genuinely competes on several fronts. Here is the fair version.

The 44.18% is the grievance, and it is the government's own number. Not a lobby group's estimate — the federal business portal's worked example. An owner-manager taking profit out of an Austrian GmbH keeps a little over half of it, and adding the employer-side contributions and the Kommunalsteuer on payroll does not improve the picture.

The exit mechanics are the second one. Not because the charge is harsh — the deferral is generous, more generous than Germany's instalment regime — but because it never ends. The Austrian departure-year assessment remains amendable for as long as you hold the asset, with a self-reporting duty attached and a third-country move as a live trigger. A founder who wants a clean line under the old jurisdiction does not get one.

The third is the second-home regime. Seventy days a year, five years of commitment, a register you must keep, and an explicit statement that the risk of the forecast failing is yours. That is a workable rule for someone who has genuinely gone, and an unpleasant one for anyone hedging.

And the things we are not going to pretend are bad: 27.5% flat and final on dividends and share gains is a good regime; no wealth tax, no inheritance tax and no gift tax is better than most of Europe manages; and an Austrian holding company with a qualifying international Schachtelbeteiligung can receive dividends from — and later sell — a foreign subsidiary with profits, capital gains, losses and other changes in value left out of account, absent an election into taxability. We do not state the qualifying holding size or holding period, because we could not verify them officially. But the shape is real, and it means some Austrian founders should move themselves and leave the holding structure exactly where it is.

Can an Austrian online shop run through Cyprus?

Yes, and for an Austrian seller the honest framing is operational rather than about market access — you are inside the single market either way. What changes is where the profit lands, and how much of the monthly compliance a machine does for you.

Your Cyprus company gets a VAT number that shows up in VIES the moment a buyer checks it, applies zero-rating to intra-EU business sales where the conditions hold, and reports consumer sales across the bloc through the one-stop shop. Your buyers in Linz notice nothing at all. The bookkeeping is where these businesses actually break, because a store throws off thousands of small transactions across several currencies and processors, with a VAT treatment that changes by customer type and destination. Sumly's Shopify and WooCommerce plugins pull orders, refunds, fees and payouts into the books with the right Cyprus VAT code already attached, so the return is assembled from the sales themselves rather than rebuilt from an export in the last week of the period. The VAT feature shows it filling in as the month runs.

What happens to your existing Austrian GmbH?

It is a decision rather than a default, and the Austrian version differs from the German one because the exit charge has already looked at your shares.

Keep it Austrian. Coherent where there is continuing Austrian trade, Austrian staff, or customers who want an Austrian counterparty. But remember what sits on top: if the Austrian GmbH ends up controlling the Cyprus company, you have walked straight into § 10a rather than around it, and the 15% threshold now sits exactly where Cyprus does.

Move its management to Cyprus. This is the one founders reason backwards about. Moving the effective management of an Austrian-registered company does not relocate it, because the registered seat alone still produces unlimited Austrian liability — that provision is an or. What you create is a company resident in both places, resolved under the treaty, with real questions about what Austria taxes in the meantime. That is a Steuerberater conversation, not a form.

Wind it down and incorporate fresh in Cyprus. For most founders this is the cleanest shape, and the reason is sequencing rather than cost. The § 27 Abs. 6 measurement happens when Austria's taxing right is restricted, so what your holding is worth then is what gets deemed realised — and the Nichtfestsetzung application belongs in the return for that same year. Ordering the liquidation, the departure and the Cyprus incorporation correctly is the highest-value hour you will spend with an Austrian adviser. How to register a company in Cyprus covers the Cyprus end, and what it costs covers the money.

Part 3: How the move runs

From the decision to the first invoice out of the Cyprus company: the order, the mistakes people make before you, and two calculations worked through in full.

What does the move look like, month by month?

Timelines follow your own facts, so read this as shape rather than schedule.

• Before anything moves — and this is where we start. We bring in an Austrian adviser who takes a position on § 27 Abs. 6 for every holding and a view on valuation. Together we settle the ownership structure — personally held, or under an Austrian holding — because that decides whether § 10a is in play at all. If a family gift is part of the plan, they put the Schenkungsmeldung deadline on the same page as it.
• Month 1. We form the Cyprus company, with your books opened the day you order, start the Yellow Slip application, and line up the Cyprus home the 60-day rule requires.
• Months 1–3. We get the VAT registration done, plus social insurance, employees and UBO wherever those apply, and we get banking and EU payments working. You take up the directorship that anchors both the 60-day rule and the place-of-management story.
• Months 2–4. The Austrian dwelling has to be dealt with honestly: given up, or the Zweitwohnsitzverordnung register set up from day one with the counting started. Your Austrian adviser handles it, and we raise it now rather than later — the register is worth nothing if it starts in month nine.
• Months 3–6. You move real decision-making to Cyprus, and we set up the minuting so it is documented there. Your Austrian adviser takes SVS and pension before the departure-year return is drafted.
• The departure-year return. Your Austrian adviser files it with the Nichtfestsetzung application in it, per asset, before the assessment issues. This is the deadline everything else on the Austrian side hangs from, and we track it alongside them.
• From month 12. We apply for the Cyprus tax residency certificate and register you as non-dom. Then we keep the file clean — day counts, the register if you kept a flat, and the § 120 Abs. 3 notification if anything is ever sold.

What mistakes do Austrian founders actually make?

The expensive ones are administrative, not exotic.

Filing the departure-year return without the Nichtfestsetzung application, because a well-ranked page called the relief automatic. Reading a German article about § 6 AStG and planning for seven instalments that do not exist in Austrian law. Deregistering at the Meldeamt and believing that ended the residency question. Keeping the flat in Salzburg without keeping the register, and discovering that the second-home regime has three conditions rather than one. Coming back to Austria in year three of a five-year forecast and unwinding the whole thing. Selling the Cyprus company four years after leaving, without notifying the Austrian tax office, and meeting § 295a BAO on the tax office's timetable instead. Gifting shares to a spouse and missing the three-month report on an asset worth far more than €50,000. Running the Cyprus company from a Vienna kitchen table and finding out what place of management means. And letting an Austrian GmbH sit on top of a Cyprus IP Box company without ever checking § 10a against a threshold that moved on 29 December 2025.

Nearly all of them come from treating the move as one event, when it is a handover between two systems that each keep a file open.

Two worked examples

A consultancy distributing €200,000 of profit. Staying in Austria, the GmbH pays 23% — €46,000 — and the remaining €154,000 is distributed and hit with 27.5% KESt, or €42,350. The founder keeps about €111,650, a combined burden of 44.18%, which is the ministry's own figure arriving by arithmetic. Through a Cyprus company, the company pays 15% — €30,000 — and a non-dom shareholder distributing the remaining €170,000 meets only GeSY at 2.65%, or €4,505, keeping roughly €165,495. The single-year gap is about €53,845, and the calculator at the top of this page compounds it, because each year's saving is invested again and Cyprus does not tax the return.

A software company at €500,000 of profit with qualifying IP. In Austria the two layers give €115,000 at company level and €105,875 at shareholder level, leaving about €279,125. In Cyprus, income qualifying under the IP Box is taxed at an effective 3% — €15,000 — and a non-dom founder distributing the rest meets the GeSY ceiling at €4,770, keeping roughly €480,230. Without the IP Box, the same company at 15% leaves about €420,230. This is the profile where the difference becomes structural — and it is also the profile where the § 10a question above matters most, because an effective 3% is under the Austrian low-tax line, so the ownership structure has to be decided at the same time as the regime.

Both cases assume every euro is distributed, headline rates throughout, and a Cyprus tax residency you have actually established rather than merely intended. Your own position, your holdings, your exit-tax exposure and your timing all move the answer, which is what a meeting is for.

Part 4: Who does the work

You can do all of this yourself. Below is what that costs in time and in money, against what it costs to let us do it.

Do it yourself — or have Sumly do it

Neither route is wrong; what separates them is how much administration you are willing to carry inside a legal system you have never worked in before. Doing it yourself means the Registrar's forms and fees, a registered office you arrange, VAT and VIES registration, provisional tax twice a year, annual statements and books that survive an audit — all while managing a two-country move. The Sumly route has three prices and no fourth: formation from €950 one-time, the bookkeeping software from €39 a month, and your own Sumly certified bookkeeper at €390 a month, with books from day zero and every return prepared field by field.

The software alone runs the whole company, whether you sit in Limassol or still in Linz: invoicing, AI double-entry bookkeeping that books your documents itself, live open-banking feeds, every VAT, VIES, provisional and corporate return prepared box by box, live reports, a document inbox with its own email address, mobile receipt capture that books itself, multi-currency invoicing, team roles and the AI assistant — plus payroll at €15 per employee per month, IP Box tracking at €50 a month, Projects at €10 a month, and the e-commerce plugins.

Sumly offers all of it to everyone: a virtual address with PO box, including digital scanning of your post into your dashboard wherever you are; nominee director and secretary where a structure genuinely calls for them; the Yellow Slip, which you qualify for as an Austrian citizen; tax residency and non-dom at €750 per person; and every registration handled — VAT, social insurance, employees and UBO — filed right the first time.

Each of those is an extra, scoped to your case. Tell us what you need in the meeting and you get one clear package-deal offer covering all of it, the IP Box application included where it fits, since that is complex expert work and exactly the sort of thing to look at with you before anyone quotes a price. No hourly billing, no surprises.

Sumly, a law firm, and a traditional bookkeeping firm

Law firm vs Sumly — and what happens when a case gets complicated

Sumly is cheaper and faster, and we work WITH lawyers, not against them. When a case gets too complicated for what Sumly handles directly, we simply connect you with the right expert in exactly the legal field you need help in, and everything gets done according to best practice, always. Either way, it starts the same place: contact us.

For an Austrian founder that division of labour is the whole point. The Austrian side — the § 27 Abs. 6 position, the departure-year application, the GmbH, the SVS question — belongs with an Austrian adviser, and we will say so every time you ask. The Cyprus side arrives as a single package instead: one provider, one dashboard, four prices printed before you order. That is what makes Sumly the best choice for Austrian founders creating a company and relocating to Cyprus.

Why is Sumly the best bookkeeping system for a Cyprus company?

Sumly is the best accounting software for a Cyprus limited company — because it is built for exactly one thing, Cyprus tax law: all 16 Cyprus VAT codes mapped to the official VAT return boxes, VIES and provisional tax native, not a localization. That is a claim we will defend anywhere, and here is what sits behind it.

An Austrian founder arriving in Cyprus will be shown two locally built alternatives, Cybooks and Balabook — and we meet their former customers every week, and what they tell us, again and again: workflows that made simple bookkeeping overly complicated, rough edges and glitches, support that left them waiting — a messy experience they were relieved to leave behind.

On every one of these checkable dimensions, Sumly leads. That is a factual comparison — not a matter of taste.

Without decoration: best support, best bookkeeping software, best AI for bookkeeping, best bookkeeper, best prices — and every part of it easy to actually run. The detail is published — Sumly vs Cybooks and Sumly vs Balabook — and for the international tools you may already run in Austria, Xero, QuickBooks and Sage.

What happens when you get in touch

You do not need to have decided anything before you speak to us, and you do not need your paperwork in order.

1. The meeting. Fifteen minutes. You tell us what you own and when you want to move. We tell you which rules at home catch you, and what the Cyprus side costs.
2. We tell you what kind of case you have. If it is simple, we do all of it — company, books, residency, non-dom — at a fixed price. If it is not, we say so immediately and bring in the specialist it needs.
3. We start. The company is registered, your books open the same day, and you have one point of contact for the whole thing.

Questions Austrian founders actually ask

Frequently asked

Does Austria charge an exit tax when I move to Cyprus?

Yes, in principle. § 27 Abs. 6 EStG treats a restriction of Austria's taxing right over your shareholding as a realisation at market value, and the Finance Ministry is explicit that no act by you is required — moving abroad, gifting the shares, dying, or a change to a double tax treaty can all trigger it. But for a move to another EU state with comprehensive mutual assistance, which Cyprus is, the liability is assessed and then not levied on application. No cash leaves your account on departure.

Was the Nichtfestsetzung abolished for Austrian departures?

Not for a founder's privately held shares. The instalment regime replaced Nichtfestsetzung only in the business-asset rules of § 6 Z 6 EStG, by the AbgÄG 2015 for transfers from 1 January 2016, with the instalment period later cut from seven years to five by the JStG 2018. Private capital assets under § 27 Abs. 6 Z 1 lit. a kept the Nichtfestsetzung concept, and the Ministry's 2026 maintenance decree still works through it with fresh examples. A large share of published advice says the opposite, and it is describing either the business-asset regime or German law.

Can I apply for the deferral later if I forget?

No. The application can only be made in the tax return for the year of the move, filed before the assessment for that year issues, and it is made separately for every asset you held at the moment of departure. There is no cure afterwards — not in an appeal, not in a reopened procedure. This is the single most expensive thing an Austrian founder can get wrong on the way to Cyprus, and it is a deadline rather than a judgement call.

Does deregistering from the ZMR end my Austrian tax residency?

No. Deregistration from the Zentrales Melderegister is an act under civil registration law and has no direct effect on § 26 BAO, which asks whether you hold a dwelling you evidently use over the longer term, or whether you are present in Austria for more than a fleeting period. Six months of presence creates unlimited liability retroactively, back to the start of the stay. English-language guides routinely present the Abmeldung as the mechanism. It is not.

Can I keep my flat in Vienna after moving to Cyprus?

Only inside the Zweitwohnsitzverordnung, and only on three conditions together: your centre of vital interests abroad for at least five calendar years, no more than 70 days of use of the Austrian dwelling per calendar year, and a written register proving the day count. The switch to limited liability starts from the beginning of the calendar year after the move rather than after the five years. But the Ministry says in terms that a taxpayer relying on the relief carries the risk of failing its conditions, including by moving back early.

Do Austrian CFC rules catch a Cyprus company?

They can, and the threshold moved. § 10a KStG turns on low taxation, which the Ministry confirms is now aligned across the corporate code at 15% by BGBl. I Nr. 99/2025, up from 12.5%. The test is the effective average burden rather than the headline rate, so Cyprus's 15% sits on the line rather than comfortably above it, and qualifying IP Box income at an effective 3% sits under it. § 10a bites where an Austrian company controls the Cyprus company; a founder who has genuinely moved and holds the shares personally is outside it.

Is a Cyprus company enough on its own to move the tax residence?

No. A corporation is unlimitedly liable to Austrian corporate tax if either its place of management or its registered seat is in Austria, and the place of management is where the decisive commercial will is actually formed. A Cyprus registration directed from a desk in Graz leaves the company Austrian for tax purposes, and the entry in the Cyprus register is irrelevant to that test. Substance in Cyprus is not decoration; it is the whole basis of the position.

Does Austria still tax wealth, estates or gifts?

No. The Finance Ministry's own index of current Austrian taxes contains no Vermögensteuer, no Erbschaftssteuer and no Schenkungssteuer. What survived is paperwork: the Schenkungsmeldung under § 121a BAO, a reporting duty on gifts of cash, company and partnership shares, businesses and other assets, with thresholds of €50,000 between relatives in a year and €15,000 between other people in five years, a three-month deadline, and a penalty of up to 10% of the value.

Does Sumly advise on Austrian tax law?

No. Sumly builds and runs the Cyprus side: formation, books from day zero, Cyprus VAT, VIES, provisional and corporate returns, the Yellow Slip, and tax residency with the non-dom application. This guide restates Austria's published position with links to the official texts so you can see the shape of the decision — but whether your holding is caught by § 27 Abs. 6, and what to put in the departure-year return, belongs to an Austrian Steuerberater. Where a case needs one, we connect you with expert lawyers from our network.

Keep reading

• Every country's route to Cyprus — the departure guide for wherever you are now
• Cyprus non-dom status — the 17-year exemption in detail
• The Cyprus 60-day rule — day counting and the residency certificate
• The Yellow Slip explained — the EU registration certificate, step by step
• What changed in the 2026 Cyprus tax reform
• How to register a company in Cyprus and what it costs
• Cyprus tax benefits for foreigners — the whole picture in one place
• Non-resident company formation — if you are not moving yourself

The calculator on this page uses headline rates, an assumed 10% annual return and full distribution of profit, so it shows the shape of the difference rather than your own return. Austrian figures are stated for 2026 and are cited to the Finance Ministry and the federal business service portal, because the statute database was unavailable throughout this research; where that left a figure unconfirmed, this page says so and prints no number. Cyprus figures apply from tax year 2026. All Sumly prices exclude VAT, and government expenses on a formation are invoiced separately once your application is approved.