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

Here is the concession that belongs at the top rather than buried at the bottom. A Maltese company charged 35% whose registered shareholder claims the six-sevenths refund keeps an effective 5% with the treasury, and a Cyprus company pays 15%. On the rate for distributed trading profit, Malta wins by ten points, and no honest page about moving a business from Malta to Cyprus can begin anywhere else.

Updated for 2026 Cyprus tax law and regulations.

One provider for the whole Cyprus side of a Maltese move, from the name check to the first return

Sumly is the one-stop, fully digitalized route for a Maltese founder to create a company in Cyprus, relocate the business into it, and run it from day one. The company is registered, the books open the day you order, every Cyprus return is prepared box by box, and the tax residency, non-dom and Yellow Slip work sits with the same provider on the same dashboard. You are trading a structure that needs two entities and a specialist to explain it for one entity you can read the accounts of yourself.

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 Cyprus really beat Malta on tax?

No, and pretending otherwise would waste your afternoon. The Maltese headline is a charge of thirty-five cents on every euro of a company's chargeable income, and the shareholder refunds under article 48 of the management Act pull most of that back out again. Cyprus charges 15% from tax year 2026 and stops.

The fractions are statutory, so here they are rather than a rounded promise.

The trading line is the one that matters to most readers, and the arithmetic is not subtle: the standard claim is six-sevenths of the Advance Company Income Tax pertaining to the distributed profits, which leaves five points of thirty-five. Passive interest and royalties drop to five-sevenths, an effective ten. Where the company claimed double-tax relief on Foreign Income Account profits the six-sevenths route is closed off entirely and the claim is two-thirds of the Malta tax paid instead. Participating-holding profits carry a refund of the whole of the Malta tax paid, on a participation threshold of only 5% of the equity shares, or the same income can simply be exempted under the participation exemption. As a holding jurisdiction Malta is genuinely first class, and this page is not going to argue otherwise.

You will notice the two-thirds row carries a description rather than a percentage. The commonly quoted figure for that route is a worked outcome rather than a published rate, and we did not find it stated by any Maltese authority, so we print the fraction the statute actually contains and leave the arithmetic to your adviser and your actual foreign tax credit.

So the Cyprus argument is not a rate argument. It is an argument about how much apparatus the rate needs behind it, what that apparatus costs every year, and how it reads to the tax authority you just left. That is the rest of this page.

How does the Maltese refund actually work, step by step?

Understanding the mechanism is the whole point, because the mechanism is what you are choosing between.

First the company allocates its profits to tax accounts, and only two of them — the Maltese Taxed Account and the Foreign Income Account — carry a refund at all. That allocation decides which fraction you are on before anything else happens. Then the company pays its 35% and files. Then it distributes a dividend and issues a dividend certificate. Then, and only then, the shareholder claims. The statute is precise about who that is: the claim belongs to the person receiving the dividend, and the refund is available provided that such person is for such purpose registered in such manner as may be prescribed. The tax authority then pays out on being satisfied as to the correctness of the claim and on receipt of the company's certificate.

Three limits sit around it that stale summaries routinely drop. The refund can in no case exceed the amount of tax actually paid by the company to the Commissioner, which matters more than it sounds when relief has already reduced the charge. The claim has a window of four years from the date on which the tax becomes eligible for refund. And getting it wrong is not a correction exercise.

The penalty provision sits at article 48(10) of the management Act, and it is one of the reasons Maltese refund claims are prepared by people who do nothing else.

Doesn't the fiscal unit already solve the Maltese cash-flow problem?

It does, completely, and this is where most comparison pages are quietly out of date.

The easy attack on the Maltese system is that thirty-five points leave the business at the return date and thirty come back only after a dividend, a certificate and an official's satisfaction — a rolling float against working capital, renewed every year. That attack was fair once. Since year of assessment 2020 it has an answer. Under the Consolidated Group rules a principal taxpayer and its 95% subsidiaries may elect to be treated as a fiscal unit, and the decisive provision then taxes the unit's chargeable income at the 35% rate reduced by the refunds that would have been claimable. The unit pays the net figure up front. There is no float to finance, because there is nothing to reclaim: article 48(4) and (4A) do not apply to profits on which the consolidated treatment is claimed. It is one route or the other.

So we are not going to sell you Cyprus on a working-capital problem Malta already fixed. What the election does not fix is the shape underneath it. A fiscal unit needs a principal taxpayer and a subsidiary held to 95% of votes, of distributable profits and of assets on a winding up. That is still two companies, two sets of statutory accounts, two audits, two registered offices and two boards, sitting under one consolidated return. The election changed the timing. It did not change the architecture, and the architecture is what you actually live with.

What does the Maltese structure cost to run, as opposed to what it costs in tax?

This is the honest Cyprus case, so it deserves plain arithmetic rather than adjectives.

The refund is a shareholder claim by design. A trading company cannot hand itself back its own tax, so the standard answer in Maltese practice is a second Maltese company that owns the first and acts as the registered claimant. Everything about that second entity is real: a formation, a memorandum, directors, minutes, a registered office, statutory accounts, an audit, an annual return, a bank relationship that has to survive a review, and a set of intercompany flows that have to be documented because somebody will eventually ask about them. None of it produces revenue. All of it exists to operate a tax mechanic.

Set beside that, a Cyprus limited company is one entity. One audit, one annual return, one registered office, one board, one bank account, one set of books. The 15% is charged at the company and finished at the company; there is no claim to register, no certificate to issue, no fraction to get right and no four-year window to watch. When your accountant explains your structure to a bank, a buyer or a foreign revenue service, the explanation is one sentence long.

There is a second edge worth stating plainly, because it changes who Malta suits. The Maltese 5% is a rate on distributed profit. A company that retains its earnings to fund growth pays 35% and claims nothing, because there was no dividend to attach a claim to. Cyprus's 15% is 15% whether you distribute or reinvest. If your plan is to leave money in the business for three years and then sell it, the two systems are much closer than the headline fractions suggest — and if your plan is to pull everything out annually, Malta is genuinely cheaper and you should say so out loud to your adviser.

Did the Maltese refund system survive Pillar Two?

Yes, and if you have read otherwise, the source was probably speculating in 2023.

The evidence is on the face of the consolidated statute book. The Income Tax Management Act at the point in time 10 March 2026 still carries article 48 with the two-thirds, six-sevenths, five-sevenths and full refunds intact, and the Income Tax Act at the same point in time still charges 35%. Both are consolidated up to and including the Budget Measures Implementation Act, 2026, and that Act neither removed nor reduced the refunds.

The reason it survived is the derogation. Malta transposed the EU minimum-tax directive and then took the delay: the regulation headed election for a delayed application of the IIR and UTPR requires a Maltese ultimate parent to nominate a designated filing entity elsewhere, and provides that the UTPR percentage computed for Malta shall be deemed to be zero for the fiscal year. The only 2026 change to those regulations is administrative — an amendment extending an exemption from the filing obligation to the notification obligation. No income inclusion rule, no undertaxed profits rule and no domestic top-up tax was introduced.

What that means depends entirely on your size. Below the directive's group-revenue threshold, Pillar Two is simply not your problem and the 5% is undisturbed. Above it, a 5% Maltese effective rate is precisely the result another jurisdiction's inclusion rule is built to top up, and because Malta has declined to collect that difference itself, someone else banks it. The saving does not scale; it changes hands. Cyprus's 15% is the minimum rate, which is a dull property until the year you cross a threshold.

One more thing, said carefully. You will see a Maltese fifteen-per-cent regime referred to by an acronym on advisory blogs. We looked for it in the statute book and in the tax authority's own legislative-developments listings for 2025 and 2026, and found no Act, no legal notice and no official page establishing it. No primary source establishes that regime, so this page does not treat it as law. The same goes for the Pillar-Two-compatible grants and refundable credits Malta has signalled: signalled is not enacted, and we could not locate an instrument a founder-scale company can actually use.

What does the Maltese non-dom actually cost you personally?

Five thousand euro a year, before anything else happens.

The remittance basis itself is strong, and stronger than most. The charge falls on income wherever it arises, but for a person who is not ordinarily resident or not domiciled in Malta the tax is payable on the amount received in Malta — and, on the limb founders care about most, no tax is payable on capital gains arising outside Malta to such a person at all, remitted or not. That is a better design than most remittance regimes and it deserves credit.

Then the floor. An individual who is ordinarily resident but not domiciled in Malta, who is not already on a scheme setting its own minimum, and who derives at least €35,000 of foreign income that is not fully received in Malta, is subject to a liability of not less than five thousand euro per annum. If the real liability comes in under that, you are deemed to have received enough extra foreign income to reach it. The Global Residence Programme is a separate deal with its own numbers: 15% on foreign income remitted to Malta, with a minimum tax of €15,000, and a property condition of a purchase at €275,000, or €220,000 in Gozo or the south, or rent of €9,600 a year, €8,750 in Gozo or the south.

The Cyprus comparison is not that Cyprus is cleverer. It is that Cyprus has no annual floor at all. A Cyprus tax resident who is not domiciled there pays no Special Defence Contribution on dividends for 17 years, and dividends sit outside Cyprus personal income tax entirely, so what is left on an extracted dividend is the health contribution at 2.65% on income up to €180,000 a year — a maximum of €4,770, and nothing if you take nothing. A shareholder who is Cyprus-domiciled pays 5% on dividends from 2026 profits instead. Salary meets bands running 0% to €22,000 rising to 35% above €72,000. The mechanics are set out in Cyprus non-dom status.

Does Malta charge an exit tax when the company leaves?

It does, and for most readers of this page it is the largest single number in the whole move — larger than any annual rate difference, and payable once.

The rule charges a taxpayer on capital gains calculated at the market value of the transferred assets at the time of exit less their value for tax purposes, and the limb that governs a relocation is the one that applies where a taxpayer transfers its tax residence from Malta to another EU Member State or to a third country, except for assets which remain effectively connected with a permanent establishment in Malta. Read that exception twice. It is the drafting on which sensible sequencing turns.

Why it hurts more than founders expect: the charge lands on unrealised value. Goodwill, the brand, the codebase, the contract book and the customer list are all assets with a market value and, very often, a value for tax purposes close to nothing. A services or software business whose balance sheet shows fifty thousand euro of equipment and whose enterprise value is two million exits on something close to the whole two million, not on the fifty thousand. Nothing has been sold. No cash has arrived. The charge is computed under the Income Tax Acts all the same, at a company rate of thirty-five cents in the euro.

The instalment machinery sits at regulation 5(2) to (4). The practical conclusion is uncomfortable but simple: the exit charge is a function of when you move, not of where you move to. Migrating before the business has accreted value, or leaving the intellectual property effectively connected with a Maltese permanent establishment while the trade moves, are decisions with a bigger euro consequence than the entire rate comparison at the top of this page. They are also Maltese decisions, which means a Maltese adviser, before anything is filed anywhere.

Do Maltese CFC rules catch a Cyprus company?

They can, and the thing to understand is that the rule keys off you rather than off the company's address.

An entity is a controlled foreign company where both limbs are met. Control is a direct or indirect participation of more than 50% of voting rights, of capital, or of the profits, counting associated enterprises. The low-tax limb compares the actual corporate tax paid abroad with what the Income Tax Acts would have charged — the familiar less-than-half test, written the long way round. On a 15% Cyprus charge against a 35% Maltese comparator, that limb is not going to save you.

What decides real cases is the third element. Where the rule bites, Malta includes non-distributed income from non-genuine arrangements, and an arrangement is non-genuine by reference to the significant people functions which are relevant to the assets and risks generating the income — and only where those functions are carried out in Malta. So the rule aims at the founder who moves the company and stays put himself: more than half the shares, a lower foreign charge, and the decisions still being taken over coffee in Sliema. The carve-outs are real but small — accounting profits of €750,000 or less with non-trading income of €75,000 or less, or profits of 10% or less of operating costs — and they are not a plan.

The clean answer is that the founder moves too, and moves properly. It is also worth noting the prior question, which arrives before CFC ever does: a Cyprus company whose real decisions are taken in Malta is exposed to Maltese residence by management and control in the first place, and the treaty then decides the matter on place of effective management. The CFC rule is Malta's second line of defence, not its first.

One Cyprus-side interaction is worth flagging because it changes the arithmetic for product companies. Qualifying intellectual property income in Cyprus falls to an effective 3% from tax year 2026 under the IP Box, which widens the gap against a Maltese comparator and therefore makes the low-tax limb even easier to satisfy. That is not a reason to avoid the IP Box. It is a reason to have moved the significant people functions before you claim it. 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 why it is scoped in a meeting rather than priced on a page: see the IP Box service.

How does Maltese tax residence actually end?

By leaving, not by counting. This is the section that separates a move that works from one that produces a letter three years later.

The published rules are unusually candid. More than 183 days in Malta makes you resident for the year regardless of why you were there. Someone arriving to establish residence becomes resident from the date of arrival, whatever the day count says. And ordinary residence is a separate, stickier concept: the authority's own formulation is that a person who lives in Malta on a permanent or indefinite basis is ordinarily resident, and that it can be acquired by coming regularly over a long period — around three years is the illustration given — and establishing personal and economic ties, without ever crossing 183 days in any single year.

Losing it works the same way in reverse. An ordinary resident loses the status by leaving permanently or indefinitely; a temporary absence does not do it unless the absence is or becomes inconsistent with a residence status, which turns on the ties retained. In practice that means a founder who moves to Limassol but keeps the Sliema apartment, keeps chairing the Maltese company, leaves the family in place and flies back most months has left himself an argument to lose. At that point the day count stops mattering and the treaty tie-breaker does the work instead: permanent home, then centre of vital interests, then habitual abode, then nationality.

The published statement of all this is on the tax authority's own residence page, and it repays reading before you book flights: a person who lives in Malta on a permanent or indefinite basis is ordinarily resident in Malta.

What does the Malta–Cyprus treaty actually do for you?

Less than people hope on withholding, and everything on residence.

The agreement is Legal Notice 139 of 1994, in force on 7 October 1994, as modified by Malta's implementation of the multilateral instrument. Its rate ceilings are conventional: dividends paid by a Cyprus-resident company to a Maltese beneficial owner bear a Cypriot charge of no more than 15% of the gross amount, with 10% ceilings on interest and on royalties. In practice those ceilings rarely do any work, because neither domestic law imposes withholding on outbound dividends to non-residents in the first place.

The article that decides your case is the corporate tie-breaker. Where a company is resident in both states under domestic law, it is deemed resident where its place of effective management is situated — not where it was incorporated. That single line is why the choice between the two departure routes is not really a choice at all. Continuing the Maltese company out to Cyprus under the registry's continuation procedure is the clean route, and it is the route that triggers the exit charge. Leaving the Maltese company incorporated where it is and simply moving the decisions does not shed Maltese residence, because a Malta-incorporated company is Maltese by incorporation; it creates dual residence, which the treaty then resolves on effective management, while leaving a Maltese filing obligation behind you indefinitely. Cheaper to start. Considerably worse to live with. We are not publishing registry fees or a processing time for the continuation route because we could not verify current figures; expect weeks rather than days, and expect tax and creditor clearances.

What does duty cost when you unwind the Maltese shareholding?

More than founders budget for, and the argument is usually about valuation rather than about rate.

Transferring shares in a Maltese company is a duty event. The charge is two euro for every hundred euro, or part of it, of the consideration or the real value, whichever is higher. Read the words "or the real value" as the operative ones: a transfer at book value between related parties is not a way around it. Where the company holds Maltese immovable property to the relevant extent, the duty is increased by a further three euro per hundred, taking it to five per cent. The tax authority's Property Tax Directorate vets the valuation and will send its own architect where property values look understated, so the realistic budget line is a valuation exchange, not a filing fee.

If the apartment is going too, price that separately and early. A transfer of Maltese immovable property attracts duty of five euro for every hundred euro of the higher of consideration and value on the buyer's side, and the seller meets a final property transfer tax of 8% of the transfer value, or 10% where the property was acquired before 1 January 2004. That is a charge on gross value rather than on gain, which means a sale at a loss is still taxed. It is one of the few Maltese numbers that is genuinely worse than it looks.

What Malta does not charge is also worth stating, because it removes a whole category of anxiety: there is no annual net wealth tax, and no estate tax as such — the page the authority publishes under the heading of inheritance describes a notarial and duty procedure on Maltese immovables rather than a tax on an estate. Cyprus is in the same position on both counts, so this is one dimension where the move changes nothing.

What happens to your Class 2 contributions and your pension?

Maltese self-employed social security is genuinely light, and this is a point in Malta's favour that Cyprus does not answer.

Class 2 contributions are due from anyone deriving more than €910 a year from an economic activity who is not employed. For 2026, for a person born from 1962 onwards, the rate is 15% of annual net earnings between €12,543.73 and €29,083.35, and above that a flat €83.89 per week, computed on the preceding year's net profit. Capped at that weekly figure, a Maltese self-employed contribution tops out around four and a half thousand euro a year. Say it plainly: on social security, Malta is cheap and most of Europe is not.

Moving inside the EU does not lose you what you paid in. Contribution records aggregate under the EU coordination regulation, Maltese history is preserved, and a pro-rata Maltese pension remains payable to you abroad. We are not publishing a deregistration checklist or a minimum-contribution-years figure, because the official pages carrying them were not retrievable when this was researched and a wrong number here would be worse than no number.

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 actually give a Maltese founder?

One rate, one company, and a shorter explanation.

The company pays 15% from tax year 2026 on profit, with no tax accounts to allocate to, no fraction to determine and no claimant to register. Qualifying intellectual property income falls to an effective 3% from tax year 2026 under the IP Box, which for a product business is the single largest structural difference on this page and the one place Cyprus goes below Malta's headline trading outcome. On the shareholder side the non-dom exemption runs for 17 years with no annual minimum tax attached to it, which is the direct answer to Malta's €5,000 floor.

Operationally, nothing structural changes: both are EU Member States inside the same VAT system, so your European trading, VIES obligations and one-stop-shop position carry over. Cyprus VAT registration begins at €15,600 of taxable turnover at a standard rate of 19%. Cyprus levies no net wealth tax and no inheritance tax, as Malta does not. What changed in 2026 is summarised in the Cyprus tax reform guide, and the head-to-head on the two company types lives at Cyprus vs a Maltese company — this page is about the move, not the scoreboard.

How does a Maltese founder become Cyprus tax resident?

Through the 60-day rule, usually, and your EU citizenship makes the immigration half trivial.

One route is simply spending over 183 days of the year on the island. The alternative now has four conditions, after the fifth was removed from the 60-day rule for 2026: 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 you own or rent. The condition that disappeared was the requirement not to be tax resident anywhere else, which matters to a Maltese founder specifically: Maltese ordinary residence can survive your departure for a while, and Cyprus no longer disqualifies you simply because Malta still has an argument. Directing your own Cyprus company is normally the office the third condition wants, so the incorporation and the residency are one project rather than two. The day counting is set out in the 60-day rule guide.

Because Malta is in the EU, the Yellow Slip — the registration certificate for EU citizens exercising free movement — is available to you as a registration rather than a permission, and it is one of the four services Sumly sells directly. The step-by-step is in the Yellow Slip explained.

Why do people choose Cyprus over other tax havens?

Because it is a country with a life attached rather than a mailbox with a rate on it — and, for a Maltese reader specifically, because it is the one alternative that gives you a Mediterranean island and English without the two-company apparatus.

Violent crime is among the lowest anywhere in the European Union. English runs through business, banking, professional services and the courts, so a Maltese founder loses nothing at all in translation and the sworn-translation invoices that plague other moves never appear. The population is already from everywhere, so nobody is the only foreigner in the room. Business and real estate are both busy, and the state lets people trade without wrapping every step in process. Meat, fruit and vegetables cost visibly less than they do in most of the EU. And the coast finishes the argument: in a Cyprus winter you can still swim, and the summers are what people cross the continent for.

The Maltese push list has to be honest, because the corporate rate points the other way. It is the second company and the professional fees underneath it. It is a structure that only makes sense once a specialist has explained it, which becomes a problem the first time a bank, a buyer's due diligence team or a foreign revenue service asks. It is a 35% headline that a company reinvesting its profits actually pays. It is the €5,000 non-dom floor. It is banking and account opening on an island whose correspondent-banking history and grey-listing episode still shape the questions being asked in 2026, and a refund structure that invites more of them. And it is substance perception: a Maltese trading company held by a Maltese holding company at a 5% effective rate is a shape a German, Dutch or Nordic revenue service recognises on sight and probes, while a Cypriot company at 15% with a director, an office and staff in Limassol reads as an ordinary operating business. The legal substance requirement is comparable. The audit-selection experience is not.

Can a Maltese e-commerce brand run through Cyprus?

Yes, and the honest framing is narrower than the version sold to non-EU sellers. Malta and Cyprus are both inside the EU VAT system, so you are not buying single-market access — you already have it. What changes is the tax position of the entity and, more practically, the quality of the ledger underneath it.

That second half is where stores actually lose money. A shop generates thousands of small transactions across several currencies with a VAT treatment that shifts by customer type and destination, and a one-stop-shop return is only ever as good as the coding beneath it. The Shopify and WooCommerce plugins pull orders, refunds, fees and payouts straight into the books with Cyprus VAT codes already applied, so the return is produced out of the sales rather than reconstructed from a CSV in the last week of the quarter.

Two worked examples

A consultancy distributing €400,000 of trading profit every year. Run through a properly structured Maltese group, the effective corporate cost on distributed trading profit is 5%, so roughly €20,000. Run through Cyprus at 15%, it is €60,000. Malta is €40,000 a year better on the rate and we are not going to dress that up. Against it, set two companies rather than one, two audits, two annual returns, the registered claimant's own compliance, and either a refund claim filed and defended every year or a fiscal-unit election that has to be maintained. On the shareholder side the positions are closer than the corporate line suggests: Malta's imputation means no further tax on the dividend, and Cyprus's non-dom means no Special Defence Contribution for 17 years with the health contribution capped at €4,770. If your business looks like this one and you are content with the apparatus, Malta is the cheaper answer.

A software company with the IP, worth €2 million, with €50,000 of assets on its balance sheet. Here the arithmetic inverts twice. First, the exit charge: transferring tax residence out of Malta is charged on market value less value for tax purposes, and for this company that difference is most of the €2 million, taxed at a company rate of 35% and payable whether or not anything was sold — deferrable over five years only if the Commissioner approves the written request, and collapsing the moment the assets are disposed of. Second, the destination: qualifying IP income in Cyprus carries an effective 3%, below anything the Maltese refund produces on trading profit. So the annual comparison favours Cyprus and the one-off comparison punishes the move, which makes timing the entire decision. Moving before the value accretes is a different transaction from moving after it, and the difference is measured in hundreds of thousands.

Both examples assume full distribution, headline treatment and no reliefs we have not researched. Your own tax-account allocation, your foreign tax credits, whether a fiscal unit is already in place and what your business is actually worth on the day you move all change the answer, which is what the meeting is for.

Part 3: How the move runs

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

What does the move look like, month by month?

Timelines depend on your circumstances, so read this as shape rather than schedule.

• Before anything — and this is where we start. We put a Maltese adviser from our network on a valuation view and an exit-charge estimate, in writing. Together we settle between continuation out and a management-and-control move, knowing the first triggers the charge and the second leaves dual residence. If a fiscal unit is in place, they tell you how it unwinds before anything moves.
• Month 1. We register the Cyprus company — ordered online, with the books open the same day — and start the Yellow Slip registration, which as an EU citizen is a registration rather than an application. Your Maltese adviser requests your contribution record.
• Months 1–3. We complete the Cyprus VAT and, where relevant, social insurance, employees and UBO registration, and get banking and EU payments working. You take up the directorship the 60-day rule needs.
• Months 3–6. You take the Cyprus home the residency test requires, and we tell you what qualifies. You move real decision-making across and we minute it there, because place of effective management is the treaty article your whole position rests on. Your Maltese adviser deals with the Maltese entity on their own timetable, including the written instalment request if you are relying on it.
• From month 12. We apply for the Cyprus tax residency certificate and register you as non-dom. Your adviser keeps dismantling the Maltese ties: an ordinary-residence argument is won by the absence of ties, not by the presence of a certificate.

What mistakes do Maltese founders actually make?

Almost all of them come from treating this as a rate decision.

Comparing 35% against 15% and concluding Cyprus is cheaper, when the refund makes it 5%. Comparing 5% against 15% and forgetting that the 5% only exists on profit you distribute. Repeating the cash-flow float argument to an adviser who then points out that a fiscal unit removes it, and losing the room. Moving the company while staying in Malta yourself, and meeting the CFC rule's significant-people-functions test head-on. Assuming Maltese ordinary residence ends because the day count did. Transferring the shareholding at book value and discovering that duty is charged on real value, with the Property Tax Directorate's own architect forming a view. Selling the Maltese apartment at a loss and still meeting an 8% charge on gross transfer value. Migrating the company after the IP has appreciated rather than before. Missing the written request for the five-year instalments, then paying the exit charge in one go. Selling the transferred assets a year later and collapsing the deferral you did get. And believing a page that told you the refund system was abolished by Pillar Two, when the consolidated statute at 10 March 2026 says otherwise.

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 are real routes and Maltese founders take each. Doing it yourself means the Cyprus Registrar's forms and fees, sourcing a registered office, VAT and VIES registration, provisional tax twice a year, annual statements and books an auditor will sign — while simultaneously running an exit-charge negotiation and a residence argument in another country. Sumly publishes three prices for that work and hides none of them: formation from €950 one-time, the bookkeeping software from €39 a month, and a Sumly certified bookkeeper of your own at €390 a month, with the books open from day zero and every return prepared box by box.

The software alone is enough to run and operate the company, whether you are already in Limassol or still filing in Valletta. It covers invoicing, AI double-entry bookkeeping that posts your documents itself, live open-banking feeds, all VAT, VIES, provisional and corporate returns 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 — with payroll at €15 per employee per month, IP Box tracking at €50 a month, Projects at €10 a month, and the e-commerce plugins alongside.

Everything else in the catalogue is offered to you too: the Yellow Slip, which your EU citizenship makes straightforward; a virtual address with PO box, mail scanned into your dashboard wherever you happen to be; nominee director and secretary where a structure calls for them; tax residency and non-dom at €750 per person; the registrations bundle covering VAT, social insurance, employees and UBO; audit through Partner Auditors; and banking and EU payments support.

Each of those is an extra, scoped to your file. Tell us what you need in the meeting and you get back one clear package-deal offer covering all of it, with the IP Box application in its proper place — it is complex expert work and exactly the kind of thing that should be examined with you before anyone attaches a number to it. No hourly billing, no surprises later.

Sumly, a law firm, and a traditional bookkeeping firm

Law firm vs Sumly — and what happens when a Maltese file 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 Maltese founder the division of labour is unusually clean. The exit charge, the duty on the share transfer, the ordinary-residence argument and any fiscal-unit unwind are Maltese work for a Maltese adviser, and this page sends you to one rather than pretending otherwise. The Cyprus company, the books, every Cyprus filing, the Yellow Slip and the residency run through one provider, one dashboard and four published prices. That is what makes Sumly the best choice for Maltese 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. What follows is the evidence, laid out so each line can be checked rather than believed.

A founder arriving from Malta will be shown two Cyprus-built products, 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.

Said plainly: the best support, the best bookkeeping software, the best AI for bookkeeping, the best bookkeeper and the best prices, with the whole thing made easy. The detail is published: Sumly vs Cybooks, Sumly vs Balabook, and against the international tools you may already run, Xero, QuickBooks and Sage.

What happens when you get in touch

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

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

Questions Maltese founders actually ask

Frequently asked

Is a Cyprus company cheaper than a Maltese one?

On the rate, no. A Maltese company is charged 35%, and a registered shareholder receiving a dividend out of ordinary trading profits may claim six-sevenths of it back, which leaves five cents in every euro with the Maltese treasury. A Cyprus company pays 15% and that is the end of it. If the rate on distributed trading profit is the only variable you care about, stay in Malta — we would rather write that sentence than have you find it out later. What Cyprus is cheaper at is everything around the rate: one company instead of two, one audit, one annual return, and no shareholder claim to register, file and defend.

Doesn't the fiscal unit remove the wait for the Maltese refund?

It does, and any page that sells you Cyprus on the cash-flow argument alone has not read the Consolidated Group (Income Tax) Rules. Rule 6(2) taxes the fiscal unit at the 35% rate less the refunds that would have been claimable on a distribution, so the net rate is paid up front rather than recovered afterwards, and rule 6(3) then switches article 48 off for those profits. You get one route or the other, never both. What the election does not remove is the second company: the unit needs a principal taxpayer and a 95% subsidiary underneath it.

Did Malta's refund system survive Pillar Two?

Yes. The consolidated Income Tax Act and Income Tax Management Act, at the point in time 10 March 2026 and both consolidated up to the Budget Measures Implementation Act 2026, still carry the 35% charge and the article 48 refunds in the same terms. Malta transposed the EU minimum-tax directive and elected the delayed application of the IIR and UTPR, with Malta's UTPR percentage deemed to be zero. The only 2026 amendment to those regulations extends an exemption from a filing obligation to a notification obligation. Nothing was abolished.

What is the Maltese 15% 'FITWI' regime I keep reading about?

We could not establish it. No Act, no legal notice and no Malta Tax and Customs Administration page setting out a final income tax without imputation at 15% was found on legislation.mt or in the authority's own legislative-developments listings for 2025 or 2026. We are not going to describe an unenacted proposal as if it were law, and you should treat any page that quotes a rate for it as unsourced until it shows you the instrument.

Does Malta charge an exit tax when the company leaves?

Yes. Under regulation 5(1)(c) of the ATAD implementation regulations, a taxpayer that transfers its tax residence from Malta is charged on the market value of the transferred assets at the time of exit less their value for tax purposes, except for assets that stay effectively connected with a Maltese permanent establishment. The charge lands on unrealised value, which for a software or brand business is most of what it is worth. Payment can be spread over five annual instalments where the destination is an EU Member State and the Commissioner has approved a written request, with interest running and a guarantee available where recovery looks at risk.

Will Maltese CFC rules catch my Cyprus company?

They can, and the trigger is where you are rather than where the company is. The control limb needs more than 50% of votes, capital or profit entitlement. The low-tax limb compares the actual foreign charge with the Maltese one. The part that decides cases is regulation 7(2), which measures whether an arrangement is non-genuine by reference to the significant people functions, and only where those functions are carried out in Malta. A founder who moves the company to Limassol but keeps running it from Sliema is the exact fact pattern the rule was written for. Carve-outs apply below €750,000 of accounting profits with non-trading income under €75,000, or where profits are under 10% of operating costs.

How does Maltese tax residence actually end?

Not by counting days out. The authority's own statement is that a person living in Malta on a permanent or indefinite basis is ordinarily resident, that ordinary residence can be built up over roughly three years of ties without ever crossing 183 days in a single one, and that it is lost by leaving permanently or indefinitely rather than by being temporarily absent. An absence has to become inconsistent with residence status, judged on the personal and economic ties you kept. Keep the apartment, the family and the board seat and you have kept your argument.

What does the Maltese non-dom actually cost?

Five thousand euro a year, as a floor. Article 56(27) of the Income Tax Act imposes a minimum liability of €5,000 on an individual who is ordinarily resident but not domiciled in Malta, is not on a scheme that sets its own minimum, and derives at least €35,000 of foreign income that is not fully received in Malta. Where the actual liability falls short, you are deemed to have received enough additional foreign income to reach it. On the Global Residence Programme the numbers are different again: 15% on foreign income remitted, with a €15,000 minimum. The Cyprus non-dom has no equivalent annual floor.

Can I get the Cyprus Yellow Slip as a Maltese citizen?

Yes. Malta is an EU Member State, so a Maltese citizen exercising free movement registers rather than applies, and the Yellow Slip is the registration certificate for that. It is one of the four services Sumly sells directly. That makes the immigration half of this move genuinely simple compared with the founders from outside the EU these guides are usually written for, and it means the difficult questions on your file are Maltese tax questions, not Cypriot permission ones.

Does Sumly advise on Maltese tax?

No. Sumly builds and runs the Cyprus half: the company, the books from day zero, Cyprus VAT, VIES, provisional and corporate returns, the tax residency and non-dom application, and the Yellow Slip. The exit charge, the duty on unwinding your shareholding, the ordinary-residence argument and the fiscal-unit unwind belong with a Maltese adviser, and this page cites the statute so you can see what to ask them. Where a case needs specialist legal work 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 vs a Maltese company — the two company types, head to head
• Cyprus non-dom status — what the 17-year exemption actually covers
• The Cyprus 60-day rule — day counting and the residency certificate
• The Yellow Slip explained — the EU citizen's registration, step by step
• How to register a company in Cyprus and what it costs
• Cyprus tax benefits for foreigners and the 2026 reform

The calculator on this page models the Maltese outcome a properly structured group actually reaches — an effective 5% corporate charge with no further tax on the dividend — rather than the 35% headline, because modelling the headline would flatter Cyprus dishonestly. It assumes full distribution and an assumed 10% annual return, and it does not model the exit charge, the duty on unwinding your shareholding, the €5,000 non-dom minimum tax or the cost of running a second company. Maltese figures are taken from the consolidated statutes on legislation.mt at the point in time 10 March 2026 and from the Malta Tax and Customs Administration. 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.