Skip to main content

Denmark → Cyprus · 2026

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

You get in touch. We form the company, act as your secretary and representative in Cyprus, give you a registered office with your post forwarded, run the accounting system and the bookkeeper, arrange the auditor and connect your payment and sales tools. For the side back home, we put you in front of the right adviser.

  • 100% approval guarantee
  • Books open the same day
  • One contact the whole way
  • 30 days free, no card

How it works

  1. 1You get in touchFifteen minutes. We hear what you do and tell you what applies to you.
  2. 2We do the workCompany, secretary, address, books, auditor, VAT and residency. Needs a lawyer, we bring one.
  3. 3You carry onOne dashboard, one contact, every deadline prepared before it falls due.

And the whole guide is below

8 sections on the rules where you are now — the exit charge, when residency actually ends, what follows you afterwards, and the move month by month. Every figure sourced to the government that published it.

We do all of thisCompany formationSecretary and representativeRegistered officeAccounting systemBookkeeperAuditorVAT, VIES and provisional taxResidency and non-domIntegrationsLawyer network, both countriesFrom €950 — 1,200+ founders have done it

Relocation calculator

What does the move actually leave you with?

Put in what your company earns and what you have invested. The calculator runs both routes side by side for ten years — and compounds every tax variable, year on year, the way real money actually behaves.

€100,000

Before any tax, in euro.

€0€1,000,000+
€10,000

What you already have working for you.

€0€2,000,000+

Staying putDenmark

You keep, per year€45,240
Tax on one year's profit€54,760
Effective rate on profit55%

Through Cyprus 🇨🇾

You keep, per year€82,748
Tax on one year's profit€17,253
Effective rate on profit17%

Ten years, compounded

Each year's take-home joins the pot first and the whole balance compounds — so the difference is not ten times one year's tax, it is everything that tax would have earned.

Year 1
+€43,578
Year 2
+€93,549
Year 3
+€150,670
Year 4
+€215,780
Year 5
+€289,811
Year 6
+€373,794
Year 7
+€468,872
Year 8
+€576,313
Year 9
+€697,516
Year 10
+€834,034

Denmark Cyprus10 years · 10% assumed annual return

More wealth after ten years in Cyprus

€834,034

Your wealth grows 132% faster in Cyprus

From €950 one-time — that's all we charge to create your Cyprus company 100% approval guarantee — if the company isn't approved, you get every euro back. All prices exclude VAT. Government and other actual expenses are invoiced separately once your application is approved.

Illustrative figures using headline rates, an assumed 10% annual return and full profit distribution. Your own bands, reliefs and timing change the result — the guide below states the real rules with their sources, and a meeting is where your actual numbers get run.

Sunset over the sea on the Cyprus west coast, with a low flat-topped island offshore and small boats drawn up along the shore

Denmark to Cyprus in 2026: register a Cyprus company, move your business, and get the fraflytterskat right

Sumly's ultimate guide on how to relocate from Denmark to Cyprus in 2026. We create your Cyprus company for only €950 and run the books from there. Here's how.

In this guide8 sections

Leaving Denmark for Cyprus does not begin with a Cypriot company. It begins with a Danish deemed disposal: on the day your full Danish tax liability ends, your shares are treated as sold at market value and taxed as aktieindkomst. The charge is deferrable, interest-free and, inside the EU, security-free — but the filing never stops.

Updated for 2026 Cyprus tax law and regulations.

One provider for the Danish exit and the Cyprus arrival

Sumly is the fully digitalized, one-stop route to starting a company in Cyprus, moving your business there from Denmark, and operating it from the day the certificate lands. We take care of the incorporation, open the books from day zero, prepare each Cyprus return box by box, and deliver the Yellow Slip, the tax residency registration and the non-dom application as fixed-price services. One dashboard and one set of prices told upfront — rather than a Danish adviser for the exit, a Cypriot lawyer for the incorporation, a bookkeeper somewhere for the accounts, and nobody at all holding the two halves together.

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 Denmark charge an exit tax when you leave for Cyprus?

Yes. Denmark runs a deemed-disposal exit tax on shares under aktieavancebeskatningsloven, and it is triggered either when full Danish tax liability ceases or when you become treaty-resident in another state. Deregistering an address is not the test. Skattestyrelsen's guidance is direct about the mechanics, and the popular Danish name for the regime — havelågebeskatning, taxation at the garden gate — is a fair description of what it does.

Three parameters decide whether it reaches you at all.

ParameterThe rule
Value thresholdIt applies where your shares have a total market value of DKK 100,000 or more on the departure date, and regardless of value where any share has a negative acquisition sum
History testIt normally bites only if you have been subject to Danish taxation of share gains for at least seven years in aggregate within the last ten before departure, or acquired the shares with succession into a transferor's tax position
RateThe deemed gain is taxed under the ordinary aktieindkomst rules: 27% up to DKK 79,400 and 42% above it for 2026, with the threshold rising to DKK 89,600 in 2027

The seven-year test is the most useful planning fact in this entire guide, and almost nobody leads with it. A founder who arrived in Denmark four years ago, or who spent several of the last ten years taxable somewhere else, walks out with no deemed disposal to defer and no henstandssaldo to maintain. That is a completely different move from the one a Danish-born founder of a twenty-year-old ApS is making, and the two should never be planned from the same checklist.

Note also what aktieindkomst is, because English-language material mangles it constantly. It is one basket holding both dividends and share gains, with a single progression threshold and no labour-market contribution on top. There is no separate "Danish capital gains tax on shares" to look up. The 42% that applies to your exit gain is the same 42% that applies to next year's dividend, which is why the ceiling on a Danish founder's own money is the 42.0% skatteloft on capital income rather than the 44.57% personal-income ceiling.

Why is the "seven years, one seventh a year" rule the wrong rule?

Because it belongs to a different tax. This is the most valuable correction in the guide, and it is worth being blunt about it: Danish bank pages, adviser blogs and consumer-finance explainers routinely describe exit-tax henstand as running "for a maximum of seven years, with one seventh falling due each year". Applied to shares, that is simply not the law.

The seven-year instalment regime is the ATAD-derived exit tax on business assets and permanent establishments in kildeskatteloven. The regime that catches a founder's shareholding is a different one, in aktieavancebeskatningsloven, and it has no fixed term. Nothing falls due after year one. Nothing is written off after year seven. The balance sits there until an event in the statute draws it down, or until you break the reporting duty.

Getting this backwards is not an academic error. It produces two opposite and equally expensive mistakes: founders who sell in year three because they believe the clock is running out anyway, and founders who stop filing in year eight because they believe the regime expired. Both are costly, and both come from reading a page that was describing somebody else's tax.

What are the beholdningsoversigt and the henstandssaldo?

They are the two artefacts that make a Danish departure permanent as an administrative relationship, even when it is generous as a tax bill. Both are created at the moment you leave, and both live for as long as any deferred tax remains.

The beholdningsoversigt is an inventory of every share you owned on the departure date, with its acquisition data. It is a closed list. Shares you buy afterwards are not on it and are outside the regime entirely — which is a planning fact in its own right, because it means new ventures started after the move are, from the Danish side, simply not part of this machinery.

The henstandssaldo is the running balance of deferred exit tax. It only ever goes down, and it can never go below zero.

Deferral is not automatic. You apply for it by filing the exit-tax return — form 04.065, with an English edition 04.065 EN, due by 1 July in the year after the year of departure. Miss that first deadline and the deemed gain becomes immediately payable in full. And once granted, the deferral carries an annual duty: while any balance remains, form 04.065 must be filed every year by 1 July, reporting the year's gains, losses and events on the listed shares.

Two things Denmark does not ask for, and they are the reason this regime is far more livable than its reputation. There is no interest charged on the deferred amount. And there is no security to post when the move is within the EU or the Nordic countries — only a move outside that circle needs satisfactory security for the deferred amount. Cyprus is an EU member state, so a Danish founder relocating here posts nothing and pays nothing to carry the balance.

Set those two features side by side and the honest summary writes itself: Denmark does not make it expensive to leave. It makes it impossible to be finished.

What makes the Danish henstandssaldo fall due?

Five events plus the filing failure, and the list is drawn so that the balance is paid down as if you had never left. Skattestyrelsen sets it out in Den juridiske vejledning, and the specific triggers matter far more than the headline, because several of them are things a founder does without thinking of them as a realisation.

EventWhat happens to the balance
Disposal of a share on the beholdningsoversigtGain or loss computed per share from acquisition cost and sale price, and the balance is drawn down accordingly
Dividends on listed sharesPayment computed under the aktieindkomst rules — and this reaches both Danish and foreign shares on the list
Value-reducing distributions and corporate eventsBonus-share allocations, debt forgiveness and similar events draw down the balance by the value of the distribution
Loans from a listed company or its subsidiariesPayment equal to the loan amount, with exceptions for loans to wholly owned subsidiaries and from credit institutions where the holding is under 5%
DeathAll shares on the beholdningsoversigt are deemed disposed of and the balance settles

The dividend trigger is the one that catches people. A founder who has moved to Cyprus, holds a Cyprus company that was already on the beholdningsoversigt at departure, and starts distributing from it, is drawing down a Danish tax balance with every distribution — even though the money never touches Denmark and the company is Cypriot. Foreign dividends are expressly inside the rule. The way around it is sequencing, not argument: what is on the list at departure is what stays on the list.

The shareholder-loan trigger is the second surprise. Borrowing from your own company is treated as payment on the balance in the amount of the loan. A director's current account run casually the way many Danish owner-managers run one becomes, from the moment of departure, a stream of taxable events.

Does Danish CFC taxation catch a Cyprus company?

It can — and the reason is the hardest fact in this guide, so we are going to state it without softening. Selskabsskatteloven paragraph 32 has no foreign-rate carve-out at all. Skattestyrelsen's own guidance says so in terms: the provision applies to all subsidiaries regardless of where they are domiciled and what the level of taxation is.

Read that again with the marketing you have probably been shown in mind. Almost every country-comparison page treats CFC rules as a low-tax filter: your subsidiary escapes if its effective rate clears some fraction of the parent country's rate. That is the classic ATAD design and it is how Finland, Sweden and several others built theirs. Denmark did not. There is no test for you to pass by pointing at a Cypriot corporation tax assessment. Cyprus's 15% is simply not part of the question.

What Denmark filters on instead is control and income composition:

  • Control. The rules apply where the Danish parent has bestemmende indflydelse — more than 50% of the votes in the company. A founder-owned structure is over that line by construction.
  • Income composition. The subsidiary is caught where its CFC income for the year exceeds one third of its total taxable income. This is the ATAD minimum-standard threshold, brought into Danish law by the 2021 amending act.
  • Measurement. Where inclusion happens, the subsidiary's income is recomputed under general Danish tax rules with statutory modifications — so the tainted slice is measured against Danish 22%, not Cypriot 15%. The arbitrage on that slice does not shrink; it disappears.

The regime reaches Danish companies and foundations alike. And this is precisely why a half-measure fails for a Danish founder. The structure a great deal of relocation content quietly assumes — keep the Danish holding company, put a Cyprus operating company underneath it, run the business from the island — is the exact shape SEL paragraph 32 was written to catch, and no amount of genuine Cypriot substance or genuine Cypriot tax changes that analysis.

There is a further sting for product companies, and it is worth naming even though it sounds like an argument against ourselves. Royalty and other intellectual-property income is classic CFC income. A Cyprus company built around the IP Box, held under a retained Danish parent, will find the one-third test very easy to fail — and the answer to "but it pays Cypriot tax" is that the statute already told you the rate does not matter.

So the structures that actually work for a Danish founder are the ones where there is no Danish parent left: you have genuinely ceased Danish residence, and the Cyprus company is held personally. Which pushes the entire question back onto the exit tax and the residency test — and that, unglamorous as it is, is the honest shape of the Danish story.

How does Danish tax residency actually end?

Through bopæl, and bopæl is a question about housing rather than about paperwork. Full — unlimited — tax liability attaches under kildeskatteloven to a person with bopæl in Denmark, and Skattestyrelsen's guidance is unambiguous that it is the actual housing circumstances that decide. CPR registration and a postal address carry no independent weight of their own.

The statutory question is whether you have, by establishing a household, renting a home or by other arrangements, signalled an intention to be domiciled in Denmark. So it is objective housing plus subjective intention, assessed together. In practice, disposal over a helårsbolig — a year-round dwelling — is both necessary and normally sufficient. A sommerhus does not usually create bopæl unless it is actually lived in year round. Secondary indicators such as a Danish-registered car or club memberships feed the overall picture without deciding it.

The trap for a founder is the home kept "just in case". Full liability ends only when the Danish dwelling is genuinely given up. Keep a helårsbolig at your disposal and bopæl survives — which means worldwide Danish taxation survives with it, the 22% and 42% exposure has not ended, and, awkwardly, the exit tax has not been triggered either. You are in the worst of both positions: still paying Danish tax, and still holding an unresolved departure. Danish practice does treat a home as given up where it is let on a lease the owner cannot terminate for a substantial fixed period, but we are not printing a number of years for that here, because we could not verify the current wording against Skattestyrelsen's own text. Get it confirmed rather than copied from a blog.

The six-month rule, and why the retroactivity matters

There is a second route into full liability that has nothing to do with owning property. A person without bopæl becomes fully liable by staying in Denmark for at least six months. Two details make this sharper than it looks:

For a Cyprus-based Danish founder that is the return-visit budget, and it is stricter than the day counts people carry in their heads. A long summer in Denmark with a fortnight in Cyprus in the middle is one stay, not two. There is a narrow exception: someone present purely for study or holiday becomes liable only after exceeding 365 days within a two-year period — but a founder taking meetings is not a tourist, and should not plan as one.

One more point on the company side, because Danish search results are dominated by it. Most of the material about "moving a business abroad" is really about ledelsens sæde — whether real management stayed in Denmark. It is a genuine issue and pro-forma directors do fail it, but it is company-level analysis and it is not what decides a founder's move. The individual's exit tax and the individual's bopæl decide it. The company question follows.

Is the Denmark–Cyprus double tax treaty actually in force?

Yes, and this needs stating because Denmark has form. Denmark denounced its treaties with France and Spain in 2008, leaving Danish residents in those countries without treaty relief for years, and the memory of it makes "is there even a treaty?" a live question for readers. For Cyprus the answer is clean.

ItemPosition
Signed11 October 2010, replacing the 1981 agreement
In force12 May 2011, implemented in Danish law by lov nr. 377 af 2. maj 2011
Effective from1 January 2012, and modified by the MLI from 1 January 2021
Dividends, art. 1015% generally, 0% for a qualifying parent holding at least 10% for at least a year
Interest and royalties0% — taxable in the residence state only
Capital gains, art. 13The treaty omits the OECD-model land-rich-company clause, so gains on shares fall to the residence-state catch-all

Three practical readings follow. First, the omitted land-rich clause is the treaty foundation for a founder who has genuinely become Cyprus-resident and later sells shares: post-departure growth falls to the residence state. It does not undo the exit tax, which crystallised under Danish domestic law before the move — the two operate on different slices of the same gain, and confusing them is how people talk themselves into a structure that does not work.

Second, if you keep a Danish ApS or A/S and take dividends from it while living in Cyprus, the domestic Danish withholding of 22% is reduced by the treaty to 15% for an individual shareholder. The 0% rate needs a qualifying corporate parent, not a person.

Third, 0% on interest and royalties means the plumbing between the two countries is genuinely clean. That is worth conceding: Denmark's treaty position with Cyprus is modern and MLI-covered, which paradoxically makes an honest relocation easier here than from countries with a stale or denounced treaty.

A pale limestone headland rising over a grey pebble-and-sand beach in Cyprus, with white surf breaking under a cloudy sky
Petra tou Romiou on the south-west coast. Even the overcast days here are the ones a Dane would call mild.

Does Denmark have a wealth tax, and what about boafgift?

No wealth tax, and a real estate duty. Denmark has not levied a net wealth tax for decades — formueskat was phased out in the mid-1990s, and none of the ministry's current statutory rate tables carries a wealth-tax line. We are deliberately not printing an abolition year, because the ministry's own historical documents would not open cleanly and a date we cannot read is a date we will not publish. The point for a founder is structural rather than chronological: Denmark taxes flow, not stock. There is no annual charge on the value of your company.

What does exist at the end is boafgift, and it reaches the company. According to Borger.dk, an estate pays 15% above a bundfradrag on what passes to close family, with a 25% tillægsboafgift on top for everyone else, and a spouse or registered partner is exempt. The combined effective burden on a non-close heir works out at roughly 36.25% on our own arithmetic from those two rates. Gaveafgift follows the same 15% shape above an annual allowance for close family.

Now the honest bit, because two official sources disagree and we would rather show you the disagreement than pick one silently. Borger.dk states the bundfradrag as DKK 346,000 for 2025 and DKK 392,300 for 2026. The Skatteministeriet rate table for boafgiftsloven gives DKK 285,700 for 2026 and DKK 392,300 for 2027. The two pages agree on 392,300 and disagree by a full year about when it applies; the 285,700 line is most likely a base amount in a different indexation year rather than the figure actually applied. We use Borger.dk's mapping here, because it is the citizen-facing statement of the law in force — and we are telling you about the conflict so that you check the current year's figure before anything depends on it. For the same reason we are not quoting a kroner figure for the annual gaveafgift allowance: it comes from the table whose year-mapping we have just flagged.

One departure-specific note on property. Ejendomsværdiskat is charged at 5.1 per mille up to the progression threshold and 14 per mille above it, on a base of 80% of the property valuation, and — this is the part that matters here — foreign property is inside the net. A Dane who is still fully liable and buys a home in Cyprus is taxed on the Cypriot property too. So ejendomsværdiskat on a Cyprus house is not an independent trap; it is a symptom that the departure has not actually happened.

What happens to folkepension and ATP when you move to Cyprus?

Folkepension travels, conditionally, and the supplements do not travel by themselves. Borger.dk states that Danish pension is payable within the EU/EEA, Cyprus included, subject to an optjeningsprincip: the base condition is having lived in Denmark for 30 years before becoming a pensioner, with an alternative route requiring at least 10 years, or a quarter of the time from age 15 to the award, continuous and running up to retirement. Short of full residence you get a pro-rata pension rather than nothing.

The supplements are the part people are caught by. Personligt tillæg, varmetillæg and ældrecheck are not paid abroad automatically — you must apply to Udbetaling Danmark for them after you have moved. You must also report the move so Udbetaling Danmark can assess whether the stay abroad is temporary or permanent, and a pensioner living abroad has to confirm annually that they are alive for payment to continue.

On ATP Livslang Pension we will be qualitative rather than precise. It is a funded, earned entitlement and is paid wherever the pensioner lives, and ATP must be told about the move so payment can continue. The mechanics — payment currency, how small balances are handled, and how the treaty allocates the taxing right — were not something we could verify against ATP's own text, so we are not printing them.

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.

What does the Cyprus side look like for a Danish founder?

Structurally flatter, and the difference is at the shareholder layer rather than the company layer. A Cyprus limited company pays 15% from tax year 2026 on taxable profit — one rate, no bands. Income from qualifying intellectual property is charged at an effective 3% from tax year 2026 under the IP Box, which is a very large number for a Danish software or product company — and which is exactly the income the CFC section above says must be structured with no Danish parent above it.

Then the owner takes the money out, and this is where the two systems stop being comparable by a few points. A Cyprus tax resident who is not Cyprus-domiciled is exempt from Special Defence Contribution on dividends for 17 years of Cyprus residence, and personal income tax does not reach the dividend either. What remains is GeSY at 2.65% on income up to €180,000 a year, so a maximum of €4,770 whatever you distribute. A Cyprus-domiciled shareholder pays 5% on dividends from 2026 profits instead, which is why the non-dom registration is done at the same time as the residency.

Compare the two ends of the pipe on one euro of pre-tax company profit, fully distributed. In Denmark: 22% selskabsskat, then 42% aktieindkomst on what is left, which is 1 − 0.78 × 0.58 = 54.76% — our arithmetic on the two statutory rates, not a quoted figure. In Cyprus, for a non-dom: 15%, then GeSY on the distribution up to its ceiling. That is the gap a Danish founder is actually looking at, and it is why the corporate headline of 22% is the wrong number to argue about.

If you take a salary in Cyprus, it runs through personal bands of 0% to €22,000 rising to 35% above €72,000. On the VAT side, taxable turnover of €15,600 obliges the company to register, and the standard Cypriot rate a Dane will be charging is 19%. And Cyprus levies no net wealth tax and no inheritance tax — the second of which is the one that means something to a Dane, given boafgift.

How does a Danish founder become Cyprus tax resident?

Most get there through the 60-day rule, and 2026 loosened one of its conditions. The route everybody has heard of is spending more than 183 days a year here. The alternative asks for far fewer days and rather more commitment on the ground, which suits someone still unwinding a Danish company.

For tax year 2026 there are four conditions rather than five, because the fifth was removed from the 60-day rule: at least 60 days in Cyprus; not 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 dropped was "not tax resident anywhere else" — which was precisely the awkward one for a Dane whose bopæl question was not yet fully resolved.

Two of those conditions do double duty in a Danish move. The third condition asks for an office in a Cyprus tax-resident person, and a seat on the board of your own Cyprus company satisfies it. And the permanent home in Cyprus, in your own name, is evidence on the Danish side that your housing situation has genuinely relocated — the thing kildeskatteloven actually weighs. We run the two projects together rather than in sequence for that reason.

Because Denmark is in the EU, the immigration side is the straightforward part. The Yellow Slip — the registration certificate for EU citizens exercising free movement — is available to you, and it is one of the services we sell outright. The mechanics are in the Yellow Slip explained and the service itself is at Yellow Slip. The tax residency certificate and the non-dom registration are a separate, fixed-price service; the detail sits in Cyprus non-dom status and the 60-day rule.

Why do people choose Cyprus over other tax havens?

Because it is a place with a normal life attached, which most of the alternatives are not. The tax is why a Danish founder starts reading; it is rarely why they stay.

Cyprus operates in English — business, banking and professional services all run in it, so a Dane's working day needs no third language. Violent crime rates here are among the lowest in the European Union, which weighs heavily for anyone arriving with school-age children. So many nationalities have already settled that nobody is the only foreigner in the room. Commerce and property are both busy, and the state's instinct toward someone starting a business is to welcome it rather than to regulate it first. Groceries — meat, fruit, vegetables — cost noticeably less than in a Danish supermarket. And the calendar itself changes: in a Cyprus winter you can still go to the beach, and the summers are what people cross a continent for. For someone used to a Danish February, that is not a footnote.

Now the honest Danish push list, which is narrower and more technical than the internet suggests.

What is real. The shareholder layer: 22% at company level is unremarkable, but extracting your own money costs 42% above a threshold measured in tens of thousands of kroner, giving the ~54.76% integrated figure above. There is no long-hold discount and no rollover for personally held shares, so an exit event is taxed at the same 42% as an ordinary dividend. CFC that a low-tax subsidiary cannot escape, which forecloses half-measures and pushes founders toward a full relocation rather than a structure. And boafgift, on a base that includes the company.

What is not real, and where the internet is wrong about Denmark. There is no Danish net wealth tax. The exit tax is not a cash-flow bomb at the border: no security inside the EU, no interest on the standing balance, no fixed instalment term. The seven-of-ten history test genuinely exempts newcomers altogether. Ejendomsværdiskat, on a base of 80% of valuation with a 5.1 per mille bottom rate, is not punitive by European standards. And the treaty with Cyprus is in force, modern and MLI-covered.

The one-line thesis, then: Denmark does not stop you leaving — it makes sure you keep filing. The exit tax is deferrable, interest-free and, inside the EU, security-free. What it is not is forgettable.

Can a Danish e-commerce brand run through Cyprus?

Yes, and for a Danish seller the question is bookkeeping rather than market access, because both countries are already inside the EU VAT system. A Cyprus company gets an EU VAT number buyers can check in VIES, zero-rates intra-EU business sales, and uses the one-stop shop for consumer sales across the bloc — the same machinery a Danish ApS uses, operated from a 15% jurisdiction.

Where a store actually breaks is volume. Thousands of small transactions a month, several currencies, a VAT treatment that shifts by customer type and country, plus platform fees, refunds and payouts that never net cleanly against sales. Our Shopify and WooCommerce plugins pull orders, refunds, fees and payouts into the books with the right VAT codes, so the return is assembled from sales as they happen rather than reconstructed from an export the week before it is due. For a Danish D2C brand used to unpicking card and instalment settlements by hand, that is usually the part that closes the decision.

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 from Denmark look like, month by month?

Timelines depend on your housing, your ApS and your buyers, so read this as shape rather than schedule.

  • Before you go — and this is where we start. We put you in front of a Danish adviser who says whether the seven-of-ten test even reaches you, values the shareholding as at the intended departure date, and works out what belongs on the beholdningsoversigt and what does not. Together we settle what happens to the helårsbolig, because that decision is the move.
  • Month 1. We form the Cyprus company, ordered online, with bookkeeping live from the moment the order goes in, and we start the Yellow Slip application. You take up the directorship that anchors the 60-day rule.
  • Months 1–3. We register for VAT and, where relevant, social insurance, employees and UBO, and get banking and EU payments moving. You rent or buy the permanent home in Cyprus in your own name, and we tell you what qualifies.
  • Months 3–6. You complete the disposal of the Danish dwelling and move real decision-making to Cyprus; we minute it there. Your Danish adviser notifies Udbetaling Danmark and ATP. We open the evidence file with you: tenancy, utilities, school registrations, day counts.
  • By 1 July of the following year. Your Danish adviser files form 04.065, applies for henstand, and receives the beholdningsoversigt and henstandssaldo. It is then filed again every 1 July, without exception, for as long as a balance remains — and we keep that date in the calendar with them.

What mistakes do Danish founders actually make?

The expensive ones repeat with depressing consistency.

Believing the seven-year instalment story and either selling early or stopping the filings. Keeping the helårsbolig for a year "in case it does not work out", and thereby never having left. Assuming the CPR deregistration did something legal. Reading a page about ledelsens sæde and thinking that is the whole analysis. Keeping a Danish holding company over the Cyprus opco and expecting Cypriot corporate tax to buy CFC protection, when the statute says the level of taxation is irrelevant. Running a shareholder loan account after departure without realising each drawing is a payment on the henstandssaldo. Distributing from a company that is on the beholdningsoversigt and treating the dividend as purely Cypriot. Spending a long summer in Denmark and discovering the six-month rule applies retroactively from day one. And assuming the supplements to folkepension will follow automatically, when they must be applied for after the move.

Nearly all of them share a root: treating the move as a date rather than as two tax systems handing over to each other.

Two worked examples

A one-person consultancy at €300,000 of profit. Through Denmark: selskabsskat at 22% takes €66,000, leaving €234,000; aktieindkomst at 42% on the distribution takes €98,280, leaving roughly €135,700 in hand — the 54.76% integrated rate above, because a distribution of this size is entirely in the upper band. Through Cyprus: 15% takes €45,000, leaving €255,000, and a non-dom shareholder meets only GeSY, capped at €4,770 — so roughly €250,200 in hand. The one-year difference is around €114,000, and the calculator at the top of this page compounds it, because each year's retained difference is also invested.

A SaaS company at €600,000 of profit with qualifying IP. In Cyprus, income qualifying under the IP Box is charged at an effective 3%, and the dividend still meets only GeSY — a structurally different position rather than an incrementally better one. But this is exactly the profile where the Danish CFC analysis has to come first, not last: IP and royalty income is classic CFC income, the one-third test is easy to fail, and paragraph 32 offers no rate defence. Held personally by a founder who has genuinely left Denmark, the structure is clean. Held under a retained Danish parent, it is the case study Denmark wrote the rule for.

Both illustrations assume headline rates and full distribution. Your seven-of-ten position, the timing of the departure and what sits on the beholdningsoversigt 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

Both routes genuinely work, and a Danish founder should pick between them with the real workload in front of them. 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 your auditor will accept — on top of a two-country move and an annual Danish filing you will be making for years. Sumly collapses the lot into three published numbers: €950 one-time to form the company, €39 a month for the software, and €390 a month if you want your own Sumly certified bookkeeper — with the books open from day zero and every return prepared box by box.

The software on its own is enough to run the company, whether you are sitting in Limassol or still in Aarhus: 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.

Do it yourself — €39/moSumly certified bookkeeper — €390/mo
BookkeepingThe AI books everything; you reviewDone for you
VAT, VIES and tax returnsPrepared — you filePrepared and submitted for you
IP BoxTracking add-on (€50/mo)Tracking run for you; the application scoped in your meeting
AuditOrder from Partner Auditors in the dashboardArranged and managed for you
Payroll€15/employee/mo add-onRun for you
E-commerce pluginsConnect Shopify or WooCommerce yourselfSet up and reconciled for you
Relocation and bankingGuides, checklists and the ordered servicesGuided end to end, with banking and EU payments sorted

And every one of these is offered to everyone who comes to us: 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 calls for them; the Yellow Slip, which as an EU citizen is straightforwardly open to you; 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 it is complex expert work and precisely the thing that should be examined with you before anyone quotes on it. No hourly billing and no surprises.

Sumly, a law firm, and a traditional bookkeeping firm

Law firmTraditional bookkeeping firmSumly
PriceQuote first, hourly billingMonthly retainer plus extrasFixed fees, told upfront
Formation guaranteeNone100% approval or your money back
ScopeFormation, then goodbyeBooks onlyFormation → books → filings → IP Box → audit → relocation
How you workEmail and waitFolders of PDFs, monthlyLive dashboard, real-time books, AI bookkeeping, mobile app
Status visibilityAsk and hopeQuarter-end surprisesLive registration and filing status
SpeedOne client among manyDeadline-season queuesAutomated and built for this journey

Law firm vs Sumly — and what happens when it gets complicated

Law firmSumly
PriceHourly rates, quote first, invoice surprisesFixed prices — formation from €950, software from €39/mo
SpeedWeeks of email back and forthOrder online in ten minutes, with live status while the Registrar works
After the formationCertificate, invoice, goodbyeBooks, VAT, VIES, payroll and filings in the same dashboard, for years
Legal depth when neededOne firm's own benchA vetted network of specialist lawyers across every relevant field

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 a Danish founder that combination is the whole argument. The fraflytterskat file needs a Danish adviser and we will say so every time you ask. The Cyprus half — the company, the books, the filings, the Yellow Slip, the residency — is one provider, one dashboard and four published prices. That is what makes Sumly the best choice for Danish founders creating a company in Cyprus and relocating their business here.

The inside of a small clothing boutique, with rails of neutral garments, shelves of shoes and pendant filament lamps under a dark timber ceiling
Independent retail on the island grew around the people who arrived for the tax position and stayed for the weather.

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 claim is defensible anywhere, and the evidence is directly below it.

The two Cyprus-built alternatives a Danish founder will be pointed at are Cybooks and Balabook. We meet their former customers every week — 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.

Generic international softwareCybooks / BalabookSumly
Cyprus VATA localization — you map the codes yourselfBuilt for Cyprus, varying depthAll 16 Cyprus VAT codes mapped to the official return boxes
VIES and provisional taxNot native — spreadsheets alongsidePartial coverageNative, generated from the books
The bookkeeping itselfYou or your accountant type it inMostly manual entryThe AI books your documents itself — you review
Company formationNoNoOrdered in-app, from €950
IP BoxNoNoQualifying income tracked, the deduction calculated
Shopify / WooCommerceVia third-party connectorsNoNative plugins
Mobile receipt captureVariesLimitedPhotograph it and it books itself
Open banking feedsVaries by marketLimitedLive feeds, reconciled automatically
Certified bookkeeper in-productNoNo€390/mo, inside the same dashboard
Entry priceVariesVariesFrom €39/mo
TrialCard usually requiredVaries30 days free, no card
Formation guarantee100% approval or your money back
SupportTicket queues, overseas hoursWhat switchers report: slow and frustratingFast, human, and actually fixes things

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

Put plainly and without hedging: the best support, the best bookkeeping software, the best AI for bookkeeping, the best bookkeeper and the best prices, with the whole of it made easy. The detail is published in Sumly vs Cybooks and Sumly vs Balabook, and for the international tools a Danish founder already uses, Xero, QuickBooks and Sage.

On the IP Box, one line bears repeating: 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 — which for a Danish owner is the same conversation as the CFC question, and they should not be held separately.

Close-up of the bonnet and LED headlight cluster of a matte metallic-blue sports coupé against a dark background
Registration and running costs on the island look nothing like the Danish ones — one of the small differences people mention first.

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 Danish founders actually ask

Frequently asked

Does Denmark have an exit tax when I move to Cyprus?

Yes, and it is one of the most complete in the EU. When your full Danish tax liability ends — or you become treaty-resident elsewhere — your shares are treated as disposed of at market value on that date and taxed as aktieindkomst at 27% and 42%. It applies where your shares are worth DKK 100,000 or more, and normally only if you have been subject to Danish taxation of share gains for at least seven years within the last ten. Skattestyrelsen calls the deferral henstand; Danish press and advisers call the whole thing havelågebeskatning.

Is the Danish exit tax really paid off over seven years, one seventh a year?

No, and this is the single most repeated error in Danish material aimed at founders. The seven-year, one-seventh instalment regime belongs to the ATAD-derived exit tax on business assets and permanent establishments in kildeskatteloven, not to shares. The share regime in aktieavancebeskatningsloven has no fixed term at all. Your henstandssaldo can sit untouched for a decade, and it falls due only on the events listed in the law — or the moment you miss a filing.

Do I have to pay interest on the deferred Danish exit tax?

No. Skattestyrelsen states it plainly in both its Danish and English guidance: no interest is charged on the deferred amount. That is a genuinely generous feature and worth saying out loud, because it means a Danish founder who moves to Cyprus and simply does not sell carries the balance at zero cost. Interest only appears once an instalment has actually fallen due and gone unpaid, and then it is punitive.

Do I have to post security to defer the Danish exit tax?

Not when you move inside the EU or the Nordic countries, and Cyprus is in the EU. Security is required only for a move to a country outside that circle. This is a concrete, checkable advantage of Cyprus over Dubai, Singapore or the UK for a Danish founder with a valuable shareholding — the same relocation, the same tax, but no capital tied up as collateral for however long the balance lives.

Does Danish CFC taxation catch my Cyprus company?

It can, and Cyprus's own tax rate does nothing to stop it. Selskabsskatteloven paragraph 32 is unusual: Skattestyrelsen's guidance says the provision applies to all subsidiaries regardless of where they are domiciled and what the level of taxation is. There is no foreign-rate carve-out to argue about. What decides it is control of more than 50% of the votes and whether CFC income exceeds one third of the subsidiary's total taxable income. The practical consequence: keeping a Danish holding company over a Cyprus operating company is not a plan.

Is there a double tax treaty between Denmark and Cyprus?

Yes. Some content still says otherwise, and it is wrong. The current treaty was signed on 11 October 2010, entered into force on 12 May 2011 and has applied since 1 January 2012, replacing the 1981 agreement. It has been modified by the MLI with effect from 1 January 2021. Dividends are capped at 15%, or 0% for a qualifying parent holding at least 10% for at least a year. Interest and royalties are 0%.

When does my Danish tax liability actually end?

When your bopæl in Denmark genuinely ends — which is a question about housing, not about the CPR register. Skattestyrelsen's own wording is that actual housing circumstances decide. A year-round dwelling that stays at your disposal keeps full liability alive no matter what your address says. Separately, someone without bopæl becomes fully liable by staying six months, and the liability runs retroactively from the first day of that stay.

Does Denmark still have a wealth tax I need to worry about?

No. Denmark has not levied a net wealth tax for decades — formueskat was phased out in the mid-1990s and none of the ministry's current rate tables carries a wealth-tax line. Danish pressure on a founder is on flow, not on stock: 22% company tax, then 27% and 42% aktieindkomst on the way out. What does survive death is boafgift, which is why the estate side belongs in the plan alongside the exit tax.

Does Sumly advise on Danish tax?

No. Sumly builds and runs the Cyprus side: the company, the books from day zero, every Cyprus VAT, VIES, provisional and corporate return prepared box by box, and the tax residency and non-dom application. This guide sets out Denmark's published rules so you can see the shape of the decision, but how aktieavancebeskatningsloven applies to your particular holding is a question for a Danish adviser. Where a case needs one, we connect you with expert lawyers from our network.

Keep reading

Figures on this page are illustrative. The hero calculator applies headline rates with an assumed annual return and full distribution, so it shows the size of the gap rather than your own outcome; Danish figures are stated for 2026, and the 54.76% and 36.25% integrated rates are our arithmetic on the statutory rates cited above rather than quoted numbers. 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.