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

Romania is the rare departure country where the honest answer starts with a concession: under €100,000 of turnover, the 1% micro-enterprise regime beats anything Cyprus can offer. Above that line the arithmetic reverses hard, because 2026 is the year the dividend tax reached 16%. This guide covers both halves, and the Cyprus company you land in.

Updated for 2026 Cyprus tax law and regulations.

Romania to Cyprus, with one partner from the first ANAF form to the first Cyprus return

Sumly is the one-stop, fully digitalized way to create a company in Cyprus, move a Romanian business onto it, and run that business from the day it exists. We incorporate, open your books the day you order, prepare every Cyprus return box by box, and deliver the Yellow Slip and the tax residency and non-dom registration as fixed-price services. One dashboard, one provider, four published prices — instead of a cabinet de avocatură for the formation, a contabil for the books, and nobody at all for the handover between two tax systems.

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.

Where does Romania still beat Cyprus for a founder?

Below €100,000 of turnover, and not marginally. The micro-enterprise regime survived the 2026 tightening as a single flat rate, and the arithmetic on a small profitable business is not close. A page that opened by telling a Romanian founder that Cyprus is cheaper would deserve to be closed on the first paragraph.

The rate is now one number. ANAF's own 2026 taxpayer notice states that from 1 January 2026 the single 1% rate applies to the taxable base at art. 53 of the Fiscal Code, and the consolidated Code shows the former 3% band and every other rate marked abrogat. A consultancy invoicing €90,000 a year pays roughly €900 of company tax. There is no Cyprus structure that competes with that.

The ceiling is where it ends. Art. 47 alin. (1) lit. c) requires revenues not exceeding the leu equivalent of 100,000 euro, tested at the close of the preceding financial year — and it is not a per-company allowance. ANAF's Cluj-Napoca notice confirms the ceiling is cumulated with the revenues of linked enterprises, so splitting turnover across two SRLs does not work, and a shareholder holding more than 25% may designate only one micro-enterprise. Add the employee condition — at least one employee, part-timers summing to a full-time equivalent, or a mandate contract paid at least at the national minimum wage — and the file-your-accounts-on-time condition, and you have a regime that is generous but conditional on five things at once.

Two more things Romania does not do badly, said plainly because they belong in an honest comparison. There is no net wealth tax — a full-text search of the consolidated Fiscal Code returns no such charge, and Cyprus has none either, so nobody wins that round. And the domestic participation exemption at a 10% holding held for an uninterrupted year, with micro-enterprise tax expressly counting as a substitute for profit tax, means a workable Romanian holding structure exists without leaving the country at all.

What changed for Romanian dividends on 1 January 2026?

The rate went to 16%, and almost nothing written about Romania has caught up. Most content still quotes 10%, which was the 2025 rate, or 8%, which was 2023 and 2024. For a founder modelling a five-year plan, that is a six-point error on every euro taken out of the company.

ANAF sets it out for each recipient. For individuals, income in the form of dividends is taxed at 16%, as a final tax, on dividends distributed from 1 January 2026 under art. VII alin. (1) lit. c) of Legea nr. 141/2025. For a Romanian legal person receiving the dividend, art. 43 alin. (2) applies a 16% rate to the gross dividend paid. And the limb that matters most once you have moved: tax due by non-residents on Romanian-source dividends is charged at 16%, withheld at the moment the income is paid.

There is one transitional rule worth knowing, because it saves money on a distribution already in flight. For dividends distributed on the basis of interim financial statements drawn up during 2025, ANAF confirms the rate stays at 10%, with no recomputation of the tax after the annual 2025 accounts regularise them.

Read the sequence rather than the rate. Sixteen percent of profit at the company, then sixteen percent of what is left on the way to the shareholder, then the health contribution on top. Take €100 of profit above the micro ceiling and the shareholder receives €70.56 before CASS. The equivalent Cyprus sequence for a non-dom is 15% and then nothing but a capped health levy.

How does CASS actually work on a Romanian founder's dividends?

Not as a percentage of what you take, which is the assumption that makes founders either panic or under-budget. The health contribution is charged at a rate of 10%, the rate provided at art. 156 of the Fiscal Code, but it is applied to a stepped, capped base rather than to the dividend itself.

The base is expressed in minimum wages, and we are going to keep it there. ANAF states that an individual owes CASS where the cumulated income for the year is at least six minimum gross national wages, and that the base is then six minimum wages between six and twelve, twelve minimum wages between twelve and twenty-four, and twenty-four minimum wages at twenty-four or above. We are not printing a 2026 lei figure for the minimum wage, because we could not verify one against an ANAF document, and a wrong number here would misstate every band on the page. Ask your accountant for the wage in force on 1 January of the year in question and multiply.

Three consequences follow from the shape rather than the number. CASS is punitive on a small distribution and negligible on a large one, because above twenty-four minimum wages of income it is a flat ceiling rather than a rate. Dividends count net and on a cash basis — what you actually received, not what was declared. And the pool that triggers it is not dividends alone: rents, royalties, investment income and other sources under the same article all aggregate into it, which is how founders who thought they were under the threshold discover they were not. It is declared on the Declarația unică, formularul 212.

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

Not on you. On the company, if you move the company. That distinction is the whole of the Romanian exit story, and most of the material online collapses the two into one warning that frightens the wrong people.

For an individual there is no deemed disposal of your shares, no charge on unrealised gains and no departure clearance fee. Nothing in the personal income title of the Fiscal Code creates one. What an individual faces on the way out is a filing obligation and an evidence problem, both covered below.

For a company, ATAD article 5 is transposed at art. 40-3, and it is precise about what it catches. Where Romania loses the right to tax the result of a later disposal, the Code takes the difference between the market value of the transferred assets and their fiscal value, and applies to any gain the rate provided at art. 17 — the 16% corporate rate. One of the listed situations is expressly the taxpayer transferring its tax residence from Romania to another Member State or a third state, other than for assets that remain effectively connected to a Romanian permanent establishment.

Do Romanian CFC rules catch a Cyprus company?

Below an effective 8%, yes. Above it, no. The arithmetic takes a minute and it is the single most useful calculation on this page, because it decides whether the IP Box is available to you in practice.

Art. 40-5 treats an entity as a controlled foreign company where the taxpayer, alone or with associated enterprises, holds more than 50% of the voting rights, capital or profit entitlement, and where the corporate tax actually paid on its profits is lower than the difference between the tax that would have been charged under Romanian rules and the tax actually paid. Decode the second limb and it says: foreign effective tax below half the Romanian rate. Half of 16% is 8%.

That asymmetry is the thing nobody tells a Romanian founder. Cyprus's headline rate is CFC-safe against Romania by a wide margin. The one Cyprus feature that transforms the arithmetic for a software business is also the one that crosses the line.

Two escapes are written into the article, and both are real. An entity carrying on a significant economic activity supported by personnel, equipment, assets and premises, as demonstrated by the relevant facts and circumstances, is outside the rules — and because Cyprus is in the EU, that escape is available. It is a substance test, not a paperwork test: a nominee-director shell with no staff and no office fails it. The second escape is a de minimis: the rules do not apply where the passive income listed in the article is one third or less of total income in the period.

One scope limit matters for how you hold the shares. Art. 40-5 sits in the profit-tax title, so it binds a Romanian company holding the Cyprus entity. A Romanian-resident individual holding Cyprus shares personally is not within it. That is not a licence to relax, because the individual's own residence then decides everything — which is the next section.

Can ANAF treat your Cyprus company as Romanian tax resident?

Yes, and this is the risk that survives a genuine personal move. It is also the point where Romania is drafted more aggressively than most of its neighbours, and where a Cyprus company is most often lost.

The Fiscal Code's definition of a resident includes any foreign legal person having the place of exercise of effective management in Romania, and it goes on to say that a resident has full tax liability in Romania, taxable on worldwide income from any source, both Romanian and foreign. Read that twice. The consequence is not a Romanian permanent establishment taxing a slice of the profit. It is the whole company becoming Romanian, taxed at 16% on everything it earns anywhere, with 16% again on the distribution.

There is no treaty rescue, either. The 1981 convention with Cyprus resolves dual company residence by reference to the seat of its effective management. So a Bucharest-managed Cyprus company loses on domestic law and loses again on the tie-breaker. Both roads lead to the same place, which means there is no structuring answer — only a factual one.

The realistic failure mode is not aggressive avoidance. It is a founder who incorporates in Limassol, keeps living in Bucharest for the first eighteen months "while things settle", and signs everything from there. What protects you is unglamorous: decisions genuinely taken and minuted in Cyprus, a board that actually decides, material spending approved on the island, books kept there, and a founder who is physically present. Our guide to nominee directors in Cyprus explains where nominees help with this and where they emphatically do not.

How does Romanian tax residency formally end, and what is the A2 chestionar?

Through a questionnaire filed before you leave, and then through evidence. This is the most procedural part of the Romanian exit and the part search results in Romanian almost never cover, which is why we are going to be specific.

Start with the tests. ANAF's own residency guide lists domicile in Romania; a permanent home in Romania, owned, rented or available at any time to you or your family; the centre of vital interests in Romania; and presence in Romania for more than 183 days in any twelve consecutive months ending in the calendar year concerned. Secondary indicators — vehicle registration, driving licence, passport, and enrolment in the Romanian social security and health insurance systems — count only in combination with those.

Then the form. Individuals resident in Romania who leave for periods abroad exceeding 183 days in total in any twelve consecutive months must complete the Chestionar pentru stabilirea rezidenței fiscale a persoanei fizice la plecarea din România — form A2, under art. 3 of OMFP nr. 1099/2016 — and ANAF's guide states that the form must be registered 30 days before departure from Romania, with the competent central tax office where the individual has his fiscal domicile. It goes in through Spațiul Privat Virtual, through e-guvernare.ro with a qualified electronic signature, in person, or by registered post.

There is a second filing most people miss. Once your Cypriot tax residence certificate arrives, you lodge a fresh questionnaire with the updated information and the certificate attached, so that the convention can actually be applied to you. And one line from ANAF's guide is worth carrying with you: where a Romanian individual leaves Romania definitively and no longer has a domicile in the country, the residence obtained in another state is not affected by occasional returns to Romania.

Does the three-year worldwide tax tail follow you to Cyprus?

No. And correcting this is probably the most valuable paragraph on the page for anyone who has been reading Romanian-language articles, because several of them state or imply the opposite.

The rule exists, and it is severe where it applies. Art. 59 alin. (7) provides that a Romanian resident individual with a domicile in Romania who proves a change of residence to a state with which Romania has not concluded a double taxation convention remains liable to Romanian tax on income from any source for the calendar year of the change and for the following three calendar years. Read the condition, not the tail. It is switched on by the absence of a treaty.

Romania and Cyprus signed their convention in Nicosia on 16 November 1981 and Romania ratified it by Decret nr. 261 of 9 July 1982. There is a treaty. The three-year tail does not apply to a move to Cyprus.

What applies instead is subtler and, for a badly documented move, worse. ANAF's guide states that a Romanian resident individual with a domicile in Romania continues to be treated as Romanian resident, with full tax liability, until the date residence changes under the convention. There is no calendar cut-off doing the work for you. The date is determined by the treaty and evidenced by your file — which is why the A2 questionnaire, the Cypriot lease, the Cypriot certificate and the Cypriot social insurance number are not administrative decoration. They are the proof that the date arrived.

What does the 1981 Romania–Cyprus treaty actually give you?

Two things worth having, and one caveat we are not going to hide. The instrument is old — signed before either country joined the European Union — and it reads like it.

A cap on Romanian dividend withholding. Art. 10 limits the source state to 10 per cent of the gross amount of the dividends, against a domestic 16% at art. 223. That is a six-point saving on every distribution from a Romanian SRL to a Cyprus-resident shareholder — but it is not automatic. ANAF is explicit that the beneficiary must present the payer with the tax residence certificate for the year in which the dividends were distributed, before payment. No certificate in the payer's hands, and 16% is withheld.

Exclusive Cypriot taxing rights over a share sale. Art. 14 assigns gains on immovable property to the state where it sits, and gains on the movable property of a permanent establishment to the state of that establishment, but other gains are taxable only in the state of residence of the alienator. There is no clause reserving Romania's right to tax gains on shares in Romanian companies. A genuinely Cyprus-resident founder selling the SRL falls under the residual rule. This is materially better than the equivalent Bulgarian treaty, which does exactly the opposite — so do not read a Bulgaria page and assume it transfers.

The caveat: Romania and Cyprus are both signatories to the multilateral instrument, and we could not verify whether the 1981 convention is a covered tax agreement, or whether a principal purpose test now overlays articles 10 and 14. Given the treaty's age, that genuinely matters. Plan on the assumption that a principal purpose test applies, because it is an OECD minimum standard: a real relocation is not what such a rule was written to catch, and a paper arrangement is.

What happens to your existing SRL?

Three routes, and it is a decision rather than a default. We will state the tax consequences we verified and stop where the research stopped.

Keep the SRL and move only the shareholder. The cleanest option. No art. 40-3 charge, because the company has not moved. Romanian profits stay taxed in Romania — 1% under the micro regime while the ceiling holds, 16% above it — and distributions to you as a Cyprus resident carry 10% under the treaty with a residence certificate, or 16% without one. Cyprus non-dom treatment then applies on what arrives. The thing to watch is that the SRL does not quietly acquire a management problem of its own once every decision is being taken from Limassol.

Migrate the SRL's residence to Cyprus. Triggers art. 40-3 at 16% on the market-value uplift, with the five-year instalment right because the destination is in the EU. Rarely the cheap answer, and never the cheap answer for a company whose value sits in its code.

Incorporate fresh in Cyprus and wind the SRL down. Any transfer of intellectual property or business assets to the new company is a disposal at market value with transfer-pricing exposure. On the winding-up itself we are deliberately silent: we did not research the ONRC dissolution procedure, its timelines, or the tax treatment of liquidation distributions against official sources, and we are not going to publish procedure we have not verified. Get that part from a Romanian adviser before you file anything.

What does Legea 239/2025 change about dividends and shareholder loans?

It tightens the classic Romanian pattern — interim dividends plus shareholder loans — into a regime with four new restrictions and fines large enough to matter, and ANAF began enforcing it in 2026. If you have been running that pattern, this section is the one to read twice.

ANAF's own communiqué sets out all four. Interim dividends suspend the company's right to lend to shareholders or affiliates until the annual accounts are approved and the interim distributions regularised, with a fine of 10,000 to 200,000 lei, with no discount for early payment and joint and several liability for the shareholder who received un-regularised interim dividends where the company also has overdue budget obligations. A company whose net assets have fallen below half its subscribed share capital may not repay shareholder loans, on the same penalty. Net assets must be restored to at least half of share capital by the end of the following financial year. And where net assets stay below the threshold and shareholder loans remain outstanding, those loans must be converted into share capital within two years, on a fine of 40,000 to 300,000 lei.

ANAF states in the same document that it is checking companies whose statutory filing deadline falls in 2026 and will penalise loan repayments made after those annual accounts were approved. This is not a rule waiting to be enforced. It is being enforced now.

What happens to your Romanian pension and health cover?

Your contribution years travel with you; your health cover has a gap in the middle. Those are two different answers and founders tend to worry about the wrong one.

On pensions, Casa Națională de Pensii Publice states the coordination principle directly: insurance periods completed in Romania and in other Member States are aggregated, with each state paying pro rata temporis for the periods completed under its own legislation, under Regulations 883/2004 and 987/2009. Your stagiu de cotizare is not forfeited by leaving. Romania pays its own proportional slice at Romanian pension age, and Cypriot years count towards the entitlement.

On health cover, the timing trap is concrete. ANAF's CASS material, citing the health law, notes that for employees insured status ends three months after the employment relationship ends, and for people on the self-assessed income categories it ends when the filing deadline for the relevant declaration passes without a new one. A founder who deregisters in Romania in the spring and does not complete Cypriot enrolment until the autumn has an uninsured window in between. Sequence the two, and do not assume one starts when the other stops.

We did not verify the A1 certificate procedure for continued Romanian affiliation, or the CNPP forms involved, so we are not describing them. Ask CNPP directly while you are still in the country.

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 Romanian founder?

One rate at the company, and almost nothing at the shareholder. After the Romanian stack, the striking thing is how short the description is.

A Cyprus limited company pays 15% from tax year 2026 on taxable profit — no bands, no turnover ceiling to fall out of, no regime to re-qualify for every January. Qualifying intellectual property brings the effective rate on that income to 3% from tax year 2026 under the IP Box, subject to the 8% CFC line above.

Then the distribution, which is where the gap against Romania actually opens. A Cyprus tax resident who is not Cyprus-domiciled — the non-dom position nearly every relocating founder qualifies for — pays no Special Defence Contribution on dividends for 17 years of Cyprus residence, and dividends sit outside personal income tax altogether. A domiciled shareholder would pay 5% on dividends from 2026 profits instead, which is why the non-dom registration is not optional paperwork. What remains is GeSY at 2.65% on income up to €180,000 a year — a ceiling of €4,770 however much you distribute. Against 16% on the whole distribution plus CASS, that is the structural difference.

If you draw a salary it is taxed on the personal scale, which runs from 0% to €22,000 rising to 35% above €72,000. Registration for VAT becomes compulsory once taxable turnover passes €15,600, and the standard rate charged on the island is 19%. Cyprus levies no net wealth tax and no inheritance tax. The detail lives in Cyprus non-dom status, Cyprus tax benefits for foreigners and what changed in the 2026 reform.

How does a Romanian founder become Cyprus tax resident, and does the Yellow Slip apply?

Through the 60-day rule in most cases — and yes, the Yellow Slip is open to you, because a Romanian citizen is an EU citizen.

The obvious route is more than 183 days a year on the island. The alternative asks for fewer days and more commitment on the ground, and it became easier in 2026: the old fifth condition was removed from the 60-day rule, leaving four. At least 60 days in Cyprus. No more than 183 days in any other single state. An office, an employment or a business in a person that is itself Cyprus tax resident, held for the whole of it. And a permanent home in Cyprus you own or rent.

The condition that disappeared was the awkward one — not being tax resident anywhere else — because another state's claim no longer disqualifies you by itself. For a Romanian founder that cuts both ways, and it is worth being clear about it: acquiring Cypriot residence is necessary, but what actually ends the Romanian one is the evidence that the convention's residence test has moved. The two projects run in parallel, and each supplies proof to the other. A directorship of your own Cyprus company can be the office the third condition asks for, and it is also the substance the effective-management analysis wants to see. The Cypriot lease that satisfies the fourth condition is the same lease your ANAF file needs.

Then the Yellow Slip, which is the certificate recording that you live here under EU free movement. What it registers is where you live, not how you are taxed, and those two get mixed up constantly — our guide sets out the difference and Sumly runs the application. Tax residency and non-dom sit alongside it as their own €750-per-person step, and the 60-day rule guide works through the day counting.

Why do people choose Cyprus over other tax havens?

Because it is somewhere people want to live, and most of the alternatives are places people put up with. The tax is what makes a founder look. It is almost never what makes one stay.

Violent crime here is among the lowest recorded anywhere in the European Union. The island runs in English in practice — business, banking, contracts and professional services — which removes the friction that a move to almost anywhere else in the bloc would add. People from all over the world are already here, Romanians among them, so nobody ends up being the only foreigner in the room. Business and real estate are booming. The state stays friendly and open to people who want to trade, and does not reach for regulation as its first instinct. Groceries — meat, fruit, vegetables — are affordable. And the coast: a Cyprus winter still leaves you able to spend an afternoon on the beach, while the summers are the ones people cross the world to book.

The Romanian push list is not about rates being high. At 1% micro, Romania has one of the lowest company taxes in the European Union. The push is that nothing holds still long enough to plan a five-year exit around it. Dividend tax went 5%, then 8%, then 10%, then 16% inside four years. The micro-enterprise ceiling went from a million euro to five hundred thousand, to two hundred and fifty thousand, to a hundred thousand — a ninety percent cut. The 3% micro band was abolished outright. CASS exemptions were stripped away in 2025 and the contribution restructured. Legea 239/2025 added four new distribution restrictions with fines to 300,000 lei. And the compliance surface underneath it — SPV, formularul 700, monthly formularul 100 with a different creditor code depending on who receives the dividend, formularele 205 and 207, the Declarația unică, formularul 112, the A1 and A2 questionnaires, and annual accounts whose late filing costs you the micro regime itself — is a lot of machinery for one founder to keep synchronised.

Founders can plan around a high rate. What they cannot plan around is a system that reprices itself every January. Cyprus's pitch to a Romanian founder is predictability, not cheapness, and it is worth saying so in those words.

Can a Romanian e-commerce brand run through Cyprus?

Yes, and the honest framing is operational rather than about market access — Romania and Cyprus are both inside the single market, so nothing is being unlocked. What does change is where the profit is taxed, and how much of the compliance work happens without you touching it.

A Cyprus company holds an EU VAT number any customer can verify in VIES, applies the zero rate to intra-EU business sales on the usual conditions, and reports consumer sales across the bloc through the one-stop shop. To your Romanian customers, nothing about the transaction looks different.

The place a store actually breaks is volume. Thousands of small transactions a month, several currencies, more than one payment processor, a VAT treatment that shifts with the customer's type and country, and platform fees, refunds and payouts that never net cleanly against the sales they belong to. Sumly's Shopify and WooCommerce plugins take orders, refunds, fees and payouts straight into the books with their Cyprus VAT codes already on them, so the return grows out of the sales rather than being rebuilt from an export the week before it is due. The VAT feature shows the return building itself as the quarter runs.

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?

How long each step takes depends on your own circumstances, so read the list as a shape rather than a schedule. The one fixed date is Romanian: the A2 questionnaire goes in thirty days before you leave, not after.

• Before you go — and this is where we start. We model whether you are actually above the €100,000 micro ceiling with you, counting linked enterprises. We put a Romanian adviser from our network on the departure date and on the SRL; if intellectual property is moving they price art. 40-3 first, and they pull your CNPP record.
• Month 1. We incorporate in Cyprus; the books open the same day you place the order, and we start the Yellow Slip. You sign a Cypriot lease in your own name — it is condition four of the 60-day rule and evidence in your ANAF file at the same time. Your Romanian adviser files the A2 questionnaire thirty days before departure, and we hold that date with them.
• Months 1–3. We get the Cyprus VAT registration done, plus social insurance, employees and UBO where they apply, and get banking and EU payments moving. You take up the directorship and hold the board decisions in Cyprus; we minute them and watch the health-insurance handover.
• Months 3–9. You live there. We accumulate the days, the utility accounts and the Cypriot social insurance registration. If the SRL is being kept, we get the residence certificate into the payer's hands before the next distribution — otherwise 16% is withheld instead of 10%.
• After the first full year. We apply for the Cyprus tax residency certificate and register your non-dom status, and your Romanian adviser lodges the fresh questionnaire with the certificate attached. We keep the board minutes clean — the effective-management question is asked about every year, not just the first.

What mistakes do Romanian founders actually make?

The expensive ones are rarely exotic, and they cluster in three places.

Budgeting the dividend at 10% because that is what every article says, and discovering 16% at the moment of distribution. Assuming the micro ceiling is per company and splitting turnover across two SRLs into the linked-enterprise rule. Skipping the A2 questionnaire because the fine is fifty lei, then having no dated evidence of departure when it is asked for. Believing the three-year worldwide tail applies to Cyprus and either panicking or paying tax that was never due. Distributing from a still-Romanian SRL without getting the Cypriot residence certificate to the payer first, and losing six points of treaty relief on the spot. Building the whole plan around the IP Box without noticing that its 3% effective rate sits under the 8% CFC line. Moving the SRL itself and meeting art. 40-3 on the software. Repaying a shareholder loan after approving accounts that show net assets below half the share capital. And, above all of them, running the Cyprus company from Bucharest and making it Romanian on both domestic law and the treaty at the same time.

Each one of them is avoidable with nothing more sophisticated than a calendar and a checklist. None is avoidable afterwards.

Two worked examples

A consultancy at €90,000 of turnover. Romania wins, and we are not going to pretend otherwise. Inside the micro regime the company pays 1% of turnover — about €900 — plus the founder's CASS on the distribution and the cost of keeping the employee condition satisfied. A Cyprus company on the same business pays 15% of its taxable profit. At this size the Romanian regime is the better answer, and the reason to look at Cyprus is a plan to outgrow the ceiling rather than the current year's tax.

A software company at €300,000 of profit. Above the ceiling, the Romanian stack is 16% profit tax — €48,000 — then 16% of the remaining €252,000 on distribution, another €40,320, before CASS. The founder is left with roughly €211,700 less the health contribution. In Cyprus the company pays 15%, or €45,000, and a non-dom founder distributing the remaining €255,000 pays only GeSY, capped at €4,770 — keeping about €250,200. The gap is close to €38,500 in a single year, and the calculator at the top of this page compounds it, because Cyprus does not tax the return on what you kept. If the income qualifies under the IP Box the difference widens sharply — and that is exactly the case where the 8% CFC line, and real substance in Cyprus, have to be settled first.

Both examples assume full distribution and headline rates, and neither includes the cost of running genuine substance on the island. Your own numbers, timing and the state of your ANAF file change the answer, which is what a meeting is for.

Part 4: Who does the work

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

Do it yourself — or have Sumly do it

Both routes are real, and plenty of founders take the first. Doing it yourself means the Registrar's forms and fees, a registered office you organise, the VAT and VIES registrations, provisional tax twice a year, annual statements, and books an auditor will accept — all of it while you are also moving between two countries. Sumly's route collapses that into three prices: formation from €950 one-time, the bookkeeping software from €39 a month, and your own Sumly certified bookkeeper at €390 a month, with books open from day zero and every return prepared box by box.

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

All of it is available to everyone: a virtual address with PO box, with your mail scanned digitally into the dashboard wherever you happen to be; nominee director and secretary where a structure really calls for them; the Yellow Slip, open to you as an EU citizen; tax residency and non-dom at €750 per person; and the registrations bundle — VAT, social insurance, employees and UBO — filed correctly the first time.

Each of those is an extra, scoped to your case. Tell us what you need in the meeting and you get one clear package-deal offer covering all of it, the IP Box application included where it fits, since that is complex expert work and exactly the kind of thing that should be examined with you before anyone quotes it. 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 Romanian founder that division of labour is the whole point. The Romanian side — the A2 file, the SRL, the art. 40-3 modelling — needs a Romanian adviser, and we will say so every time. The Cyprus half comes from a single provider, inside a single dashboard, at four prices printed on this site. That is what makes Sumly the best choice for Romanian founders creating a company in Cyprus and relocating their business to it.

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. We will defend that sentence in any room, and the evidence for it follows.

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

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

Said without decoration: the best support, the best bookkeeping software, the best AI for bookkeeping, the best bookkeeper and the best prices, with everything made easy. The detail is published rather than asserted — Sumly vs Cybooks and Sumly vs Balabook, plus Xero, QuickBooks and Sage for the international tools you may already be using.

On the IP Box one line is worth repeating, and for a Romanian founder it carries an extra edge because the effective rate sits under the art. 40-5 threshold: 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 first rather than last.

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 Romanian founders actually ask

Frequently asked

Is Romanian dividend tax really 16% in 2026?

Yes. Legea nr. 141/2025 took the rate to 16% for dividends distributed from 1 January 2026 onward, and ANAF states it for resident individuals, for Romanian legal persons at art. 43, and for non-residents at art. 223. The 10% that most articles still quote applied to 2025 only, and 8% before that. There is one transitional carve-out: dividends distributed on interim financial statements drawn up during 2025 stay at 10%, with no recomputation when the annual accounts regularise them.

Is a Romanian micro-enterprise cheaper than a Cyprus company?

Below the ceiling, decisively. The micro-enterprise tax is a single 1% of turnover, and the ceiling is €100,000 of revenue tested at 31 December of the preceding year and cumulated across linked enterprises. A profitable business under that line pays less in Romania than any Cyprus structure can offer. Above it the picture inverts: 16% profit tax, then 16% on the dividend, then CASS. We would rather tell you that than sell you a move you do not need.

Does Romania keep taxing me for three years after I move to Cyprus?

No, and this is the most widely repeated error in Romanian-language content. The three-year worldwide-income tail in art. 59 alin. (7) of the Fiscal Code applies only where the person proves a change of residence to a state with which Romania has no double tax convention. Romania and Cyprus have had one since 1981. What does apply is that you stay fully taxable in Romania until the date residence changes under the convention, which is why the evidence matters more than the calendar.

Do Romanian CFC rules catch a Cyprus company?

Only below an effective 8%. Art. 40-5 asks whether the tax actually paid abroad is lower than the difference between the Romanian tax that would have applied and the tax actually paid — which is the same as asking whether the foreign effective rate is under half the Romanian 16%. A Cyprus company on the standard 15% is comfortably clear. A Cyprus company running most of its income through the IP Box at an effective 3% is not, and needs the genuine-activity escape to hold.

Can ANAF treat my Cyprus company as a Romanian taxpayer?

Yes, and this is the trap that survives an otherwise clean move. The Fiscal Code's definition of a resident at art. 7 pct. 37 includes a foreign legal person whose place of effective management is in Romania, and a resident has full tax liability in Romania on worldwide income. The 1981 convention does not rescue you either: its company tie-breaker is also the place of effective management. Decisions taken in Bucharest make the company Romanian on both tests at once.

What is the A2 chestionar and when do I file it?

It is the questionnaire for establishing the tax residence of an individual on departure from Romania, under art. 3 of OMFP nr. 1099/2016. It must be registered 30 days before you leave, with the competent central tax office for your fiscal domicile, and ANAF notifies you within 15 days whether you keep full Romanian tax liability. The penalty for skipping it is only 50 to 100 lei — which is exactly why founders skip it and then cannot prove they ever left.

What happens if I move the SRL itself to Cyprus?

Art. 40-3 happens. Transferring your tax residence out of Romania, or moving assets that leave Romania's taxing right behind, is charged on the difference between market value and tax value at the 16% rate of art. 17. Because Cyprus is an EU Member State, the tax can be paid in equal instalments over five years — but the charge itself is real, it is computed at market value, and on a valuable software or brand portfolio it is usually the largest single line in the whole move.

Will I lose my Romanian pension years by moving to Cyprus?

No. Romania and Cyprus both apply the EU social security coordination regulations, and Casa Națională de Pensii Publice states the principle plainly: insurance periods completed in different Member States are aggregated for entitlement, and each state pays pro rata for the periods completed under its own legislation. Your stagiu de cotizare is not lost, it is added to your Cypriot record. Watch the health-insurance gap in the middle instead — that one is real.

Does Sumly advise on Romanian 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 the tax residency and non-dom application. This guide quotes Romania's own published rules with links to ANAF so you can see the shape of the decision, but how art. 40-3 values your intellectual property is a question for a Romanian consultant fiscal. 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 uses headline rates, an assumed 10% annual return and full distribution of profit, so it shows the shape of the difference rather than your own result. Romanian figures are stated for 2026 and cited to ANAF; the CASS bands are published in minimum wages rather than lei because we could not verify a 2026 lei figure against an official source. 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.