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

Three facts decide the France-to-Cyprus arithmetic in 2026, and most pages get all three wrong: the flat tax is 31.4%, not 30%; a 20% minimum tax floor now sits above it; and the treaty in force is still the one signed in 1981. Correct those, and the rest of the decision changes shape.

Updated for 2026 Cyprus tax law and regulations.

Everything the move from France to Cyprus needs, handled in one place

Sumly is the one-stop, fully digitalized way to create a company in Cyprus and relocate a business there from France — and then to run it, from the day it exists. We register the company, open the books the day you order, prepare every Cyprus return box by box, and take the Yellow Slip, the tax residency registration and the non-dom application as fixed-price services. One dashboard, one provider, one set of prices told upfront, instead of an avocat for the structure, an expert-comptable for the accounts and nobody for the space between them.

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.

Why is the French flat tax 31.4% in 2026 rather than 30%?

Because only half of it stayed still. The income-tax leg of the prélèvement forfaitaire unique is unchanged, but the social-levy leg rose on 1 January 2026, and the familiar round number went with it.

The PFU has always been two charges presented as one. Income tax takes 12.8% on all distributed income paid from 2018 onwards. Prélèvements sociaux take the rest, and that is what moved: the same page records that from 1 January 2026 the rate of prélèvements sociaux goes to 18.6%, against 17.2% on income paid in 2025. Service Public breaks the new rate into its parts: CSG at 10.6%, CRDS at 0.5% and the prélèvement de solidarité at 7.5%. Add the two legs and the 2026 headline is 12.8% plus 18.6%, or 31.4% in total.

Two details around the edge of that table are worth having. First, the 40% abattement that makes the barème progressif attractive to some shareholders is not available if you opt for the PFU — you choose one regime or the other, and the social levies are due either way. Second, the global option for the barème used to be irrevocable for the year; impots.gouv.fr states that from 2026 the irrevocable character of that option has been removed. That is a genuine improvement, and it is the sort of thing a page that only wants to make France look bad would leave out.

Capital gains on securities ride on the same machinery, at the same 12.8% plus social levies, under the same global option. The proportional holding-period abattements survive only under the barème and only for securities acquired before 1 January 2018; the official notice to form 2074-ETD is explicit that whatever the method of taxation, unrealised gains on securities acquired or subscribed from 1 January 2018 benefit from no proportional abattement. A founder who incorporated in 2019 has nothing to wait for.

What is the CDHR, and why does it cancel the PFU advantage?

Because it is a floor, and a flat tax is only ever a ceiling. The contribution différentielle sur les hauts revenus does not raise a rate; it tops your total up to a minimum, and the higher your distribution, the more of the PFU's benefit it takes back.

The mechanism sits at CGI article 224. It applies where the combined charge to income tax and to the CEHR is less than 20% of income, and it engages above €250,000 of reference income for a single person and €500,000 for a couple taxed jointly. It was created by article 10 of the 2025 finance law, applies from the taxation of 2025 income, and BOFiP confirms it was extended by article 2 of loi n° 2026-103 of 19 February 2026, running until the year in which the public deficit falls below 3% of GDP.

Sitting underneath it, and often confused with it, is the older contribution exceptionnelle sur les hauts revenus at CGI article 223 sexies, which is a rate rather than a floor:

Those CEHR bands are stated for income declared for 2025 and 2026. Read the two together and the picture for a founder distributing seriously changes. The 12.8% income-tax leg is well under 20%, so a large dividend year is precisely the fact pattern that trips the floor; the CEHR then rides on top of the result. Any comparison that stops at "France has a 30% flat tax" is describing a founder who never distributes much.

There is a cash-flow consequence too, and it catches people in their first big year. The CDHR is not settled quietly with the return: an acompte of 95% of the estimated contribution falls due in the first half of December, on your own estimate, in the same year the income arises.

Which France–Cyprus tax treaty is actually in force?

The 1981 one. This sounds like pedantry and is not: the two texts allocate taxing rights over share sales differently, and a plan built on the wrong one is built on law that does not yet exist.

The instrument that governs today is the convention signed at Nicosia on 18 December 1981, approved by loi n° 82-1093 of 23 December 1982 and in force from 1 April 1983. BOFiP records the same sequence in its commentary on the convention, and impots.gouv.fr's Chypre page lists the 1981 convention and its version consolidated with the multilateral instrument.

A replacement was signed on 11 December 2023. The étude d'impact laid before the conseil des ministres on 28 January 2026 says the new convention will replace the France–Cyprus convention currently in force, signed at Nicosia on 18 December 1981, and records that Cyprus notified completion of its internal procedures on 29 December 2023 while France had not. We are not going to assert what has happened since that document was published — that is exactly the kind of claim with a short shelf life that should be checked, not repeated. Check the Chypre page yourself before you act on either text.

That article matters because of what French domestic law would otherwise do. Under article 244 bis B, France taxes a non-resident on gains from selling shares in a French company liable to IS where the seller, with spouse, ascendants and descendants, held more than 25% of the profit rights at any moment in the previous five years, at 12.8% for individuals. But BOFiP applies that rule subject, where applicable, to the international tax conventions. Treaty article 14(4) is the applicable convention, so for a genuinely Cyprus-resident former French founder the gain on his French shares falls to Cyprus.

On dividends the 1981 text caps source withholding at 10% where the beneficial owner is a company holding at least 10% of the payer, and 15% otherwise, and its article 4(3) resolves dual company residence in favour of the siège de direction effective. On elimination of double taxation it uses the exemption method on the French side; the étude d'impact notes the 2023 convention switches to a credit method and that the change is not neutral.

Does France charge an exit tax when you move to Cyprus?

Yes — and it is far less frightening than its reputation, provided you are going to an EU state and you intend to hold. Cyprus is an EU Member State. The trap is not the departure. It is selling too soon afterwards, which is the opposite of what most people expect.

The charge lives at CGI article 167 bis, in the version in force since 1 January 2024. Two conditions must both be met. You must have been fiscally domiciled in France for at least six of the ten years preceding the transfer, and at the date of transfer your holdings must either exceed €800,000 in global value or represent at least 50% of a company's bénéfices sociaux. Those are alternatives, not cumulative conditions, and the second one is what catches founders: a majority shareholder of a modest company is inside the regime even nowhere near €800,000.

The tax itself is income tax at the 12.8% forfait of CGI article 200 A, with an express global option for the barème, plus prélèvements sociaux. On the social-levy leg we are going to be careful rather than confident. The only official notice we read is the 2074-ETD notice, which states 17.2% and covers transfers made in 2024. We found no official page confirming a rate for a 2026 departure, so we will not put a number on it: read it as 12.8% income tax plus prélèvements sociaux at the rate in force for your year of departure, and get that rate confirmed for the year you actually leave.

Then the two features that make Cyprus workable. The deferral is automatic: article 167 bis IV grants a sursis de paiement where the taxpayer transfers his fiscal domicile out of France to a Member State of the European Union, with no guarantee and no fiscal representative required — for non-EU destinations the deferral is discretionary and security of 12.8% of the gains is demanded. And the charge does not merely wait; it dies:

impots.gouv.fr puts it in the same terms: two years for taxpayers whose securities in the exit-tax scope are worth less than €2,570,000, five years for those above it, after which the tax is dégrevée d'office if the shares are still in the taxpayer's hands. Relief also follows a return to France, a gift of the securities, or the taxpayer's death.

Do articles 209 B and 123 bis catch a Cyprus company owned by a French founder?

They are two different rules aimed at two different taxpayers, and conflating them is the single most common error in French-language articles about Cyprus. One targets companies. The other targets individuals. Only the second is likely to concern you, and only while you are still in France.

Article 209 B applies to companies. It reaches a personne morale established in France and liable to impôt sur les sociétés that holds more than 50% of a foreign entity subject to a régime fiscal privilégié — reduced to 5% where more than half is held by French enterprises acting in concert. A founder who personally owns Cyprus Ltd shares is not a French personne morale, so 209 B has nothing to bite on. A French holding company owning the Cyprus entity is a completely different conversation. The article also carries an EU escape: it does not apply where the entity sits in a Member State and the holding cannot be regarded as an artificial arrangement designed to circumvent French tax law.

Article 123 bis applies to individuals. It reaches a personne physique domiciliée en France holding, directly or indirectly, at least 10% of the shares, parts, financial rights or voting rights of an entity established outside France in a privileged regime, and deems that entity's profits to be the individual's own revenus de capitaux mobiliers whether or not they are distributed. Note the subject of the sentence. Once your French domicile has genuinely ended, article 123 bis has nobody to tax.

The low-tax test is the same for both, and it is arithmetic rather than a list. A regime is privileged where the foreign charge is at least 40% lower than the tax that would have been borne in France. Against a French IS of 25%, that line sits at 15%. Cyprus's corporate rate is below it, so the definition is engaged — which is why the escape clause matters more than the threshold.

Two precision points, because French founders are routinely told the opposite of both:

• The notional minimum return does not apply to Cyprus. Article 123 bis contains a floor computed on net assets, but the statute introduces it only for cases where the entity is established in a State or territory that has not concluded an administrative-assistance convention with France, or that is non-cooperative. Cyprus is neither. Any article telling you a Cyprus holding triggers a deemed minimum return has read the paragraph without its opening words.
• The EU escape clause is real. Paragraph 4 bis disapplies the charge where the entity sits in an EU Member State and the holding cannot be regarded as an artificial arrangement whose purpose would be to circumvent French tax legislation. Outside that perimeter the taxpayer carries a much harder burden — showing the arrangement has principally an object and effect other than locating profits in a low-tax territory.

So the useful summary is short. If you stay in France and own a Cyprus company, 123 bis is a live question answered by substance. If you leave properly, it is not your rule at all. What survives your departure is the next section.

Can the fisc treat your Cyprus company as French anyway?

Yes, and this — not the exit tax, not the CFC articles — is what actually goes wrong for French founders in Cyprus. A Cyprus company that is really run from France is exposed on three independent grounds, and none of them cares what the Registrar in Nicosia has on file.

Territoriality. CGI article 209, I taxes profits made in enterprises exploitées en France. BOFiP explains that habitual exercise of an activity can arise through an autonomous establishment, through a complete commercial cycle carried out in France, or with no establishment at all: a company whose seat is outside France that carries out operations in France through representatives without independent professional standing is deemed to be exercising directly. A Cyprus company selling into France through someone in France who is not genuinely independent is the textbook case.

Place of taxation. Impôt sur les sociétés is assessed at the place of the legal person's principal establishment, but the administration may designate instead the place where the effective management of the company is carried on. That is a power to look past the address.

The treaty. Article 4(3) of the 1981 convention resolves dual residence of a person other than an individual in favour of the State where its siège de direction effective is situated. All three tests point at the same question, and it is not a paperwork question.

What protects you is ordinary and unglamorous: directors who actually live in Cyprus, board meetings genuinely held and minuted there, material decisions and spending signed off there, real premises, real people, and records that match the story you would tell an inspector. Our guide to nominee directors in Cyprus is honest about where a nominee helps and where it does not — and a nominee who signs whatever arrives by email is not substance, it is evidence against you.

When does French tax residency actually end under article 4 B?

When none of four separate tests is satisfied — and the reason people get caught is that any single one of them is enough on its own. A plane ticket, a Cyprus lease and a Yellow Slip settle nothing by themselves if a French criterion is still met.

Article 4 B, in the version in force since 16 February 2025, treats as domiciled in France anyone who has in France their foyer or the place of their principal stay; anyone who carries on a professional activity in France, salaried or not, unless they show that activity is carried on there on an ancillary basis; and anyone who has in France the centre of their economic interests. The article also deems directors of companies headquartered in France with annual turnover above €250 million to carry on their activity there principally — irrelevant at founder scale, but worth knowing the provision exists rather than being surprised by a mention of it.

The two limbs that catch real founders are the first and the last. Foyer is the family's habitual home, so a spouse and children staying behind in Lyon can keep you French while you personally live in Limassol. And the centre of economic interests is exactly where a founder whose income still comes overwhelmingly from a French company sits. Article 4 B closes with the override that matters: someone meeting a domestic criterion is nonetheless not treated as domiciled in France where a double-taxation convention does not regard them as a French resident. The treaty tie-breaker runs on top — permanent home, then centre of vital interests, then habitual abode, then nationality.

The practical sequence is documented, and it is short:

1. Tell your centre des finances publiques. Declare the new foreign address in your espace particulier — and create the espace particulier before you leave and keep a bank account in the SEPA zone for paying tax. Both are trivial in advance and irritating afterwards.
2. Notify your employer and pension funds, since the taxation of what they pay you changes on departure.
3. In the year following departure, file two returns for the departure year: form 2042 for income from 1 January to the date of departure, and form 2042-NR for French-source income from the date of departure to 31 December.
4. Once that return is processed, if French-source taxable income remains, your file transfers automatically to the service des impôts des particuliers non-résidents. If nothing remains, say so expressly in the free-text section rather than leaving it to be inferred.
5. Add the exit-tax forms if you are within article 167 bis.

One number to keep in view if you retain French-source income: the non-resident minimum rate of tax runs at 20% up to €29,579 and 30% above, subject to the taux moyen mechanism where it produces a better result.

Does the IFI reach a French founder's company shares?

No — and this is the correction most worth making loudly, because founders are told the opposite constantly. When the ISF was replaced, France stopped taxing wealth in general and started taxing real estate only. Shares as such, cash, portfolios and goodwill are outside the base.

The IFI is triggered where net taxable real-estate wealth exceeds €1,300,000 at 1 January 2026, and is then computed from €800,000 upward on this scale:

Estates between €1,300,000 and €1,400,000 get a décote of €17,500 less 1.25% of net taxable wealth, which softens the cliff at the threshold.

Where shares are concerned, three limits do almost all the work. Shares are taxable only to the extent of the immovable assets held by the company, never at enterprise value. Indirect real estate is not counted at all where the taxpayer holds less than 10% of the capital of the company that owns it. And real estate used for the company's own operating activity is excluded from the base outright. For a software founder whose company owns no buildings, the IFI is simply not a fact about his life.

Which cuts both ways, and we would rather say so than sell you something. "Escape the French wealth tax" is not a reason to leave for most founders, because there is no wealth tax on their company to escape. What departure does change is the perimeter: for a non-resident, the IFI reaches only immovable property and rights situated in France. A Paris flat stays in scope after you move; anything you buy in Cyprus never enters it. Cyprus, for its part, levies no net-wealth tax at all.

What happens to French inheritance tax when you leave?

It is the push factor that survives the IFI correction, and it is a real one for a founder whose wealth is concentrated in a single company — with an important caveat we will put in front of the numbers rather than behind them.

In the direct line, each parent may pass €100,000 to each child free of duty, and the taxable balance runs up a progressive scale:

Outside the direct line the numbers are harsher still: 35% then 45% between brother and sister, and 60% for an unrelated beneficiary.

The caveat, stated plainly: these are the rates before any relief on the transfer of a business. French law contains a specific regime for transmitting company shares — the pacte Dutreil, at CGI article 787 B — which can substantially reduce the taxable value of the shares passed on where its conditions are met. We did not research it for this guide and we are not going to summarise a relief we have not read, so treat the table above as the position without it and ask a French notaire or avocat fiscaliste what a Dutreil arrangement would do to your own figures before you treat succession as a reason to leave. A page that quotes 45% and stops there is giving you a false impression, and we would rather lose the headline than do that.

Cyprus levies no inheritance tax. That is a straightforward difference, and it is one of the reasons founders with children and a single concentrated asset look at the island in the first place — but the French tail on a French estate is a question for a French adviser, not for us.

What happens to your social security and your French pension?

Coordination handles most of it, and one part of it is a genuine, sourced saving. But this is also the section where we have the least to offer, and we would rather say that than fill it with numbers.

On the health side, Service Public is unambiguous that a French national who settles and works in an EU or EEA state or Switzerland is no longer insured under the French scheme and becomes subject to, and contributes to, the host country's system. Before leaving, ask your caisse for form E104, which attests to the insurance periods completed in France so the Cypriot institution can take them into account. Voluntary affiliation to the Caisse des Français de l'étranger exists as an option, though Service Public points out it is aimed principally at countries with no social security convention with France — inside the EU the coordination rules apply automatically.

On pensions, European coordination preserves what you have already earned: periods of activity completed in a Member State of the European Union are taken into account as if they had been completed in France. Contributions during your Cyprus years go to the Cypriot system; French quarters already banked are not lost. The page also warns against the assumption that periods simply add up — the calculation applies the most favourable method rather than summing EU, EEA, Swiss and UK periods together.

Where we have nothing to offer: URSSAF. Every attempt to read URSSAF's own pages for this guide failed, so we publish no contribution figures, no A1 or détachement mechanics, and no deregistration procedure for a self-employed person leaving France. The shape is that EU coordination assigns a worker to one Member State's scheme at a time and that someone permanently transferring activity to Cyprus deregisters in France — but the specifics belong to URSSAF and to a French adviser, and you should get them from there rather than from us.

What is sourced, and worth real money. Once you are no longer a French tax resident, impots.gouv.fr states that revenus de capitaux mobiliers are not subject to prélèvements sociaux if you are not fiscally resident in France. The whole 18.6% disappears from your dividends — a larger number than most of the exit-tax discussion it gets buried under. French real-estate income and gains do stay in scope, but even there the position improved: since 1 January 2019, people affiliated to a compulsory social security scheme other than the French one within the EEA or Switzerland are exempt from CSG and CRDS, leaving only the 7.5% prélèvement de solidarité. A founder who moves to Cyprus, joins the Cypriot scheme and keeps a rental flat in Bordeaux sees the social levies on that rent fall from 18.6% to 7.5%.

What happens to your existing SAS or SARL?

Three routes, with three genuinely different tax consequences. Most articles cover one of them and let the reader assume it is the only one.

It stays French and you leave. The company keeps paying IS on its profits, and the dividends it pays you as a non-resident change character entirely. A retenue à la source applies under CGI article 119 bis, 2 at 12.80%, the rate in force at 1 January 2026, subject to more favourable provisions in the tax conventions, and BOFiP confirms the same 12.8% for individuals — with a punitive 75% reserved for distributions to non-cooperative States, which Cyprus is not. Add the point from the previous section, that revenus de capitaux mobiliers bear no prélèvements sociaux for a non-resident, and the same dividend that cost 31.4% while you lived in Paris costs 12.8% at source once you do not — before Cypriot treatment. That is the single largest sourced number in this guide, and it belongs to founders who keep the French company rather than to those who dismantle it.

Its siège or an establishment moves to Cyprus with the assets. This is a corporate-level exit charge, entirely separate from your personal one, and it is where redomiciliation pitches go quiet. BOFiP explains that transferring the siège or an establishment together with fixed assets to another EU or EEA Member State does not automatically constitute a cessation where activity continues in France — but where the transferred assets are the whole of the company's assets, it leaves the French IS net, and impôt sur les sociétés is computed on the unrealised gains recognised on the transferred assets under CGI article 221, 2, together with gains previously held in report or sursis. For a company whose value sits in its software, that valuation is the whole cost of the move.

You incorporate fresh in Cyprus alongside. Nothing crystallises at French corporate level, which is why this is the common shape — and it is also precisely the configuration that puts effective management and établissement stable on the table, and, while you are still French-resident, article 123 bis. Substance is the whole of it.

One honest limit: we located no official page setting out the company-law formalities for moving a SAS or SARL's siège out of France, as distinct from the tax treatment above. The Service Public pages we found address transfers within France. Ask a French avocat what the corporate mechanics require before you assume the tax analysis is the only obstacle. Our guide to how to register a company in Cyprus covers the Cyprus end of the sequence, and what a Cyprus formation costs covers the money.

What does a French founder actually pay today?

More than the flat tax suggests, and the arithmetic is worth doing once rather than arguing about. The corporate rate is 25% as standard, with 15% on profits up to €42,500 for companies whose turnover excluding VAT is €10,000,000 or less and whose capital is fully paid up and at least 75% held by natural persons. Note that the turnover test is measured differently for a company inside a group, which can deny the reduced rate to a small subsidiary — we did not read the detailed rule, so check it if a group applies to you.

Take €100 of company profit, distribute all of it, and apply the 2026 rates. This is our own arithmetic from the sourced rates above, not a published figure:

And that is before the top of the scale. The CEHR adds 3% or 4% on reference income above €250,000, and the CDHR then pulls the whole thing up to a 20% minimum on that reference income — reclaiming precisely the advantage the PFU was designed to give. For a founder distributing serious money, the honest answer to "what does France take" is well north of half of pre-tax company profit.

Is France actually hostile to founders? A fair answer

No, and a guide that pretended otherwise would not survive contact with a French reader who has actually used the system. Three things are true at the same time as everything above.

The PFU was itself a major liberalisation. Before 2018, dividends went to the barème progressif at the top marginal rate plus social levies. Introducing a 12.8% flat income-tax leg was a deliberate and large reduction in the taxation of capital, and it has survived every budget since — the 2026 change hit the social-levy leg, not the 12.8%.

Research support is genuinely generous. The crédit d'impôt recherche runs at 30% of research spending up to €100 million and 5% above, with a higher rate in the overseas departments, and the crédit d'impôt innovation adds 20% of eligible expenditure within a ceiling of €400,000 a year, extended to 31 December 2027, with enhanced rates in Corsica and overseas. For a deep-tech company burning cash on engineers, that is real money and Cyprus has no equivalent instrument.

The jeune entreprise innovante regime still exists, but it has been narrowed, and its income-tax component in particular is not what it was for newly created companies. We did not verify the current conditions against an official page for this guide, so we put no figures on it — if JEI status is part of your case, get its present state confirmed before you weigh it.

The fair framing, then, is not that France is bad and Cyprus is good. It is that France is a good place to build a research-intensive company and an expensive place to extract profit from one. Where your own company sits on that line is the actual question, and it is a better one than any rate table.

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 French founder?

Flatter, and much shorter to describe. A Cyprus limited company pays 15% from tax year 2026 on taxable profit — one rate, no bands, no threshold to fall off, the same on €50,000 as on €5 million, and no municipal layer on top of it. Under the IP Box, income from qualifying intellectual property is taxed at an effective 3% from tax year 2026.

The gap opens when the owner takes the money out. A Cyprus tax resident who is not domiciled in Cyprus — the non-dom status nearly every relocating founder qualifies for — pays no Special Defence Contribution on dividends for 17 years, and dividends sit outside Cyprus personal income tax altogether. A domiciled shareholder, by contrast, pays 5% on dividends from 2026 profits. What remains for the non-dom is GeSY at 2.65% on income up to €180,000 a year — a ceiling of €4,770 however much you distribute. Salary, if you take one, meets the ordinary personal bands, which run from 0% to €22,000 rising to 35% above €72,000.

On the operating side, VAT registration is required above €15,600 of taxable turnover and the standard rate is 19%. There is no net-wealth tax and no inheritance tax. The whole picture is laid out in Cyprus tax benefits for foreigners, and what changed in the 2026 reform covers the rates that moved.

How does a French founder become Cyprus tax resident — and does the Yellow Slip apply?

Usually through the 60-day rule, and yes, the Yellow Slip is open to you. As a French citizen you are an EU citizen, which makes the residence side of this move markedly simpler than it is for the founders arriving here from outside the Union.

The familiar route to Cyprus tax residence is more than 183 days on the island. The alternative asks for far fewer days and more commitment on the ground, and it loosened in 2026 when the old fifth condition was removed from the 60-day rule. Four conditions remain: 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 through the year; and a permanent home in Cyprus, owned or rented. The condition that fell away was the requirement not to be tax resident anywhere else, which was awkward for anyone with a lingering French connection — competing claims now go to the treaty tie-breaker instead of disqualifying you outright.

For a French founder that matters twice over. A directorship of your own Cyprus company can be the office the third condition asks for, so incorporation and residence are one project rather than two — and the same directorship, if it is genuinely exercised, is part of the substance story that CGI article 218 A and treaty article 4(3) will test from the other side. The Yellow Slip is the registration certificate that formalises your residence in Cyprus under EU free movement; it is a residence registration and not a tax status, and confusing the two is the most common mix-up we see. Our guide explains the difference, and Sumly handles the application. Tax residency and non-dom are the separate step at €750 per person, and the 60-day rule guide walks through the day counting.

Can a French e-commerce brand run through Cyprus?

Yes, and for a French seller the honest argument is operational rather than about access — you are inside the single market either way, and we are not going to pretend a border appears where none exists. What changes is where profit is taxed and how much of the compliance runs itself.

A Cyprus company carries an EU VAT number your customers can check in VIES, zero-rates intra-EU business sales on the usual conditions, and uses the one-stop shop for consumer sales across the bloc. Your customers in Lille and Lyon notice nothing at all. What they buy, and how it is delivered, does not change.

The bookkeeping is where stores actually come unstuck, because a shop generates thousands of small transactions across several currencies and payment processors, with a VAT treatment that changes by customer type and destination. Sumly's Shopify and WooCommerce plugins pull orders, refunds, fees and payouts straight into the books with the right Cyprus VAT code attached, so the return is assembled from the sales themselves rather than reconstructed from a CSV export the week before it is due. The VAT feature shows the return building through the month instead of appearing at the end of it.

Why do people choose Cyprus over other tax havens?

Because it is a place people are willing to live in for a decade, which is not true of most of the alternatives on the list. Tax is what makes founders look at the island; it is very rarely what keeps them there.

On violent crime the island sits among the lowest-rate members of the Union. It is an English-speaking country in every practical sense — business, banking, professional services and most of the paperwork happen in English, which for a French founder is a shorter adjustment than Portuguese or Greek. People from all over the world are already here, so nobody arrives as the only foreigner in the room. Business and real estate are booming. The state stays friendly and open towards people who want to trade, without wrapping the whole thing in regulation. Groceries — meat, fruit, vegetables — cost noticeably less than in a French city. And the beaches — a Cyprus winter still lets you swim, and its summers are what people cross the world to reach.

The French push list, kept to what is documented rather than what is felt:

• Distributed profit is expensive, and the direction of travel is visible. Social levies on investment income rose 1.4 points in a single year, from 17.2% to 18.6%, and the composed burden on a euro of distributed profit is 48.55% at the standard corporate rate on the arithmetic above.
• The top of the scale is worse than the headline. The CEHR adds 3% or 4%, and the CDHR imposes a 20% minimum on reference income above €250,000 — a structure explicitly designed to take back what a flat tax gives.
• The filing tail is real and specific. A departing founder files 2042 and 2042-NR for the departure year; inside the exit tax, form 2074-ETD and then a 2074-ETS return every single year of the deferral, with the deferral lost if one is missed; and if the company's siège moves, annual declarations with a 5% penalty for omission. That is a concrete burden with citations behind it, which is a better complaint than "French bureaucracy".
• What we will not claim. We found no official quantification of France's overall administrative load, so we do not invent one. Anything you read about hours or cost per year is somebody's estimate, and we would rather leave a gap than fill it.

Two worked examples

A consultancy distributing €200,000 of profit. In France the company pays €50,000 of IS at the standard rate, and the €150,000 distributed meets the PFU at 31.4% — €47,100 — leaving about €102,900, a total burden of 48.55%. 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 €165,500. The one-year gap is about €62,600, and the calculator at the top of this page compounds it, because each year's saving is invested too and Cyprus does not tax that return.

A SaaS company at €500,000 of profit with qualifying IP. In France the two layers give roughly €125,000 of IS and €117,750 of PFU on the €375,000 distributed, leaving about €257,250 — before the CEHR and the CDHR, both of which would engage at that level of reference income and push the French figure lower still. In Cyprus, income qualifying under the IP Box is taxed at an effective 3% — €15,000 — and the non-dom founder distributing the rest meets only the GeSY ceiling of €4,770, keeping around €480,200. Without the IP Box, the same company at 15% leaves about €420,200. This is the profile where the difference stops being incremental — and it is also the profile where an article 167 bis valuation on the way out is largest, because a fast-growing software company is exactly what an earnings-based valuation rewards.

Both examples assume full distribution, headline rates, and that you have genuinely become Cyprus tax resident and Cyprus non-dom. Your own reliefs, your CEHR and CDHR position, your exit-tax exposure and your timing all move the answer, which is what a meeting is for. The savings calculator runs your own numbers.

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 France look like, month by month?

Every timeline bends to its own facts, so take what follows as a shape and not a schedule.

• Before anything is filed — and this is where we start. We put a French adviser from our network on article 167 bis: were you domiciled in France six of the last ten years, and do you clear €800,000 or hold 50% of the bénéfices sociaux? Together we settle what happens to the SAS or SARL. You create your espace particulier, and we check you have a SEPA-zone account for paying tax afterwards.
• Month 1. We create the Cyprus company; it is ordered online and the books open that same day. We start the Yellow Slip application and line up the permanent home the 60-day rule requires.
• Months 1–3. We handle the VAT registration, and social insurance, employees and UBO where they apply, and get banking and EU payments moving. You accept the directorship that anchors the 60-day rule and the substance case at once.
• Months 2–4. You end the French connections that article 4 B tests — the foyer above all — and your French adviser declares the new address to your centre des finances publiques and asks your caisse for form E104 before you go.
• Months 3–6. You move real decision-making to Cyprus and we minute it there. We sequence anything happening to the French company with your adviser rather than around them.
• The following spring. Your French adviser files 2042 and 2042-NR for the departure year, plus 2074-ETD if you are inside the exit tax. We apply for the Cyprus tax residency certificate and the non-dom registration.
• Every year after that. Your adviser files the 2074-ETS follow-up while the deferral runs, and you hold the shares to the two-year line — five years above €2.57m. We keep both dates in the calendar.

What mistakes do French founders actually make?

The expensive ones are rarely exotic.

Leaving the family in France and assuming the move is done, when foyer alone keeps you domiciled under article 4 B. Keeping every euro of income sourced from the French company and meeting the centre des intérêts économiques test without noticing. Reading an article that says the flat tax is 30% and budgeting on it. Getting through the exit tax and then selling in month twenty, throwing away a dégrèvement that was fourteen months away. Missing a 2074-ETS follow-up filing and terminating the deferral by inattention. Believing that a Cyprus company triggers a deemed minimum return under 123 bis, and paying for advice about a paragraph that does not apply to Cyprus. Believing the reverse about the IFI, and leaving to escape a wealth tax that never touched the shares. Quoting the 2023 treaty at a French inspector when the 1981 one is in force. Moving the siège with the assets and meeting the article 221, 2 charge on the software. And, most often of all, running the Cyprus company from a desk in Paris while a director in Limassol signs what arrives by email.

Almost every one of them comes from treating the move as an event rather than as a handover between two tax systems, each of which wants its share first.

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 are real, and the choice is mostly about how much administration you want to carry inside a legal system you have never used. 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 auditor — on top of a two-country move you are already running. The Sumly route carries three prices and nothing hidden behind them: formation from €950 one-time, the bookkeeping software from €39 a month, and your own Sumly certified bookkeeper at €390 a month, with the books open from day zero and every return prepared box by box.

The software on its own runs the company, whether you sit in Limassol or still in Paris: invoicing, AI double-entry bookkeeping that books your documents itself, live open-banking feeds, VAT, VIES, provisional and corporate returns all 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 prepares the returns and a person submits them: you on Do it yourself, your Sumly certified bookkeeper on the €390 plan.

Sumly offers all of it to everyone: a virtual address with PO box, including digital scanning of your mail delivered to the dashboard wherever you happen to be; nominee director and secretary where a structure genuinely needs them; the Yellow Slip, which as a French citizen you qualify for; tax residency and non-dom at €750 per person; and every registration handled — VAT, social insurance, employees and UBO, filed right the first time. Audit runs through our Partner Auditors, and we help founders get banking and EU payments sorted, without ever promising you a particular bank's decision.

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 sort of thing that should be looked 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 it 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 a French founder that division of labour is the entire point. The French half of this move — the article 167 bis position, the Dutreil question, what happens to the SAS — belongs to a French avocat or expert-comptable, and we will say so every time you ask. The Cyprus half — company, books, filings, Yellow Slip, residency — comes from one provider, through one dashboard, at four published prices. That is what makes Sumly the best choice for French 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 sentence we defend anywhere, and the evidence is below.

The two locally built alternatives a French founder will be shown on arrival 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.

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

Put plainly: the best support, the best bookkeeping software, the best AI for bookkeeping, the best bookkeeper, the best prices — and all of it done easily. The detail is published: Sumly vs Cybooks and Sumly vs Balabook, and for the international tools a French founder may already be running, 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 is one more reason the meeting comes before any quote. The IP Box service page explains what that conversation covers.

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 French founders actually ask

Frequently asked

Is the French flat tax still 30% in 2026?

No. The income-tax leg is unchanged at 12.8%, but prélèvements sociaux rose from 17.2% to 18.6% on 1 January 2026 — CSG 10.6%, CRDS 0.5% and prélèvement de solidarité 7.5%. The prélèvement forfaitaire unique for 2026 income is therefore 31.4%. Service Public sets out the composition on its own page for 2026 income. Almost every competing article still quotes 30%, which is now simply out of date.

What is the CDHR, and does it apply to a founder taking dividends?

The contribution différentielle sur les hauts revenus is a 20% minimum effective tax floor at CGI article 224, created by the 2025 finance law and extended by loi n° 2026-103 of 19 February 2026. It bites where income tax plus the CEHR together come to less than 20% of reference income, above €250,000 for a single person and €500,000 for a couple taxed jointly. For a founder distributing large dividends under the 12.8% PFU, that is exactly the situation it was written for.

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

Yes, under CGI article 167 bis, if you were fiscally domiciled in France for at least six of the ten years before the transfer and your holdings either exceed €800,000 or represent at least 50% of a company's bénéfices sociaux. But because Cyprus is an EU Member State the deferral is automatic, with no guarantee and no fiscal representative, and the charge is cancelled outright after two years — five above €2.57m — provided you still hold the shares.

Which France–Cyprus tax treaty is actually in force?

The convention signed at Nicosia on 18 December 1981, in force since 1 April 1983 and since modified by the multilateral instrument. A new convention was signed on 11 December 2023 and Cyprus ratified it on 29 December 2023, but the French étude d'impact laid before the conseil des ministres on 28 January 2026 records that France had not. impots.gouv.fr still publishes the 2023 text under a URL marked non entrée en vigueur, so check the country page before you rely on either text.

Does article 123 bis catch a French founder who owns a Cyprus company?

Only while he is still domiciled in France. Article 123 bis applies to a personne physique domiciliée en France holding at least 10% of a foreign entity in a privileged tax regime. Once French domicile has genuinely ended, the article has no subject. And the notional minimum return it contains applies only where the entity sits in a state with no administrative-assistance convention or on the non-cooperative list — Cyprus is neither, so that floor never applies to a Cyprus company.

Does the IFI tax my company shares if I stay in France?

No, and this is the point French founders are told wrongly most often. The IFI replaced the ISF and reaches real estate only. Shares are caught solely to the extent of the company's own immovable property, real estate used for the company's operating activity is excluded, and indirect real estate is not counted at all where you hold under 10% of the company that owns it. Enterprise value, cash, portfolios and goodwill are outside the base entirely.

What happens to my SAS or SARL when I leave France?

Three different outcomes, with very different costs. If it stays French, dividends to you as a non-resident bear a 12.8% retenue à la source and no prélèvements sociaux at all. If its siège or an establishment moves to Cyprus with the assets, corporate tax falls due on the unrealised gains on those assets under CGI article 221, 2, payable immediately or spread over five years. If you set up a fresh Cyprus company alongside, nothing crystallises — but that is the configuration where effective management gets tested.

Can the fisc treat my Cyprus company as French anyway?

Yes, and this is the real risk rather than the exit tax. CGI article 218 A lets the administration fix the place of taxation where the direction effective of the company is exercised, article 209, I taxes profits of an enterprise exploitée en France including through a dependent representative, and article 4(3) of the treaty resolves dual residence in favour of the siège de direction effective. A Cyprus company whose decisions are really taken in Paris is French on all three tests.

Am I still liable to prélèvements sociaux after leaving France?

Not on dividends. impots.gouv.fr states that revenus de capitaux mobiliers are not subject to prélèvements sociaux if you are not a French tax resident, so the 18.6% falls away entirely. French real-estate income and gains stay in scope, but since 1 January 2019 anyone affiliated to a compulsory social security scheme in another EEA state is exempt from CSG and CRDS, leaving only the 7.5% prélèvement de solidarité on that income.

Does Sumly advise on French tax?

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 non-dom. This guide sets out France's own published law with sources so you can see the shape of the decision — how article 167 bis values your holding, or whether a pacte Dutreil belongs in your plan, is a question for a French adviser. 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

The calculator on this page runs headline rates, an assumed 10% annual return and full distribution, so it shows the shape of a difference rather than your own outcome. The €100 illustration and both worked examples are our arithmetic from the sourced rates, not published figures, and they exclude the CEHR and the CDHR. French figures are stated for 2026 except where a source carries its own date, and the exit-tax social levies are deliberately left without a rate because no official 2026 figure was found; 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.