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

Slovenia's corporate tax rate is printed as 19% and paid at 22%, and both numbers are correct. That contradiction is the first thing to settle if you are a Slovenian founder pricing a move to Cyprus, because everything downstream — the CFC line, the integrated rate on distributed profit, the arithmetic of waiting versus leaving — is computed off it.

Updated for 2026 Cyprus tax law and regulations.

Sumly is the one provider for both halves of a Slovenia-to-Cyprus move

Creating the Cyprus company, moving a Slovenian business onto it, and running it from the day it exists are three jobs, and almost nobody sells all three. Sumly does: we incorporate, open the books the day you order, prepare every Cyprus return box by box, and handle the tax residency and non-dom registration as a fixed-price service. One dashboard, one partner, prices published up front — instead of a Slovenian odvetnik for one piece, a računovodski servis for another, and nobody at all for the part where two tax systems have to hand over to each other cleanly.

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 does Slovenian corporate tax read 19% but cost 22%?

Because the rate you pay was changed by a different act than the one that contains it, and the original was never amended to match. This is the most commonly mangled fact in Slovenian tax writing, so it is worth doing properly once.

The standing provision is ZDDPO-2 art. 60, and FURS still describes the general rate as 19%. The operative provision for the years you are actually planning is art. 64 of the Zakon o obnovi, razvoju in zagotavljanju finančnih sredstev — the reconstruction act passed after the 2023 floods — which provides that notwithstanding ZDDPO-2 art. 60, tax is paid at 22% of the tax base for the years 2024, 2025, 2026, 2027 and 2028. FURS carries the same reading on its own corporate tax landing page.

Three things follow, and each one matters to somebody.

It is a rate override, not a second tax. You compute one liability, at 22%, on the ordinary ZDDPO-2 base. There is no second return, no separate base, no surcharge line. The only thing the second paragraph of art. 64 does is send the three-point difference to the earmarked reconstruction fund under art. 127 of the same act — budget plumbing that changes nothing in your computation.

It expires by its own terms. The article lists five years exhaustively and stops. Absent new legislation, 2029 falls back to 19% without anyone doing anything. That is the legal position, and it is also the reason you should not build a ten-year plan on it: a rate that has already been legislated as temporary once can be extended by one line in a future act, and we found no basis for asserting either that it will be or that it will not.

The amending act is ZORZFS, which is why nobody can find it. People search for a "ZDDPO-2T" amendment, find nothing, and conclude the increase never happened. The DDPO act itself was genuinely never changed. The 22% lives in an entirely different statute.

One number that is easy to conflate with the rate: withholding tax on Slovenian-source payments out of the country is 15%, under ZDDPO-2 art. 70. For an outbound dividend to a Cyprus recipient the domestic EU exemption is usually reached before the treaty even comes into play, which we deal with in the treaty section below.

What does a Slovenian founder actually keep out of distributed profit?

About 58.5 cents in the euro, on headline rates. That is the comparison figure to hold in your head, and it is considerably harsher than the corporate rate alone suggests, because Slovenia taxes the distribution as a separate final event.

Dividends paid to a Slovenian resident individual are taxed at a flat 25%, withheld by the payer as a davčni odtegljaj and treated as final tax — it never enters the annual dohodnina assessment. The rate was 27.5% in 2020 and 2021 and came back down to 25% from 1 January 2022, which is why older comparisons still float around with the wrong number in them.

The 41.5% combined burden is arithmetic derived from the two published Slovenian rates rather than a figure FURS prints anywhere. On the Cyprus side, the company pays 15% from tax year 2026, and a shareholder who is Cyprus tax resident but not Cyprus-domiciled pays no Special Defence Contribution on dividends for 17 years and no personal income tax on them either, leaving only the health levy at 2.65% on income up to €180,000 a year — a hard ceiling of €4,770 however large the distribution. A domiciled shareholder would instead pay 5% on dividends from 2026 profits, which is why the non-dom registration carries the entire position rather than being an optional extra.

Paying yourself a salary in Slovenia is worse again. The 2026 dohodnina scale runs to 50% above €82,346.23 of annual net base, with 39% starting at €57,184.88, and social contributions sit underneath it: 23.10% from the employee and 17.10% from the employer for an employed director, or 24.10% and 16.10% for a self-employed person, both halves of which a founder pays out of the same business either way. Cyprus salary runs on a scale of 0% to €22,000 rising to 35% above €72,000 — higher at the top than Slovenia's first two brackets, which is precisely why relocating founders take a modest salary and take the rest as a distribution.

Does Slovenia's capital-gains taper make leaving the wrong move?

Sometimes, and honestly so. This is the strongest feature of the Slovenian personal tax system for a founder, and no Cyprus structure improves on its end state, because its end state is zero.

Dohodnina on a capital gain is a final tax, and the rate steps down for every five completed years you have held the capital. FURS states the schedule directly: 25%, falling to 20% after five completed years of holding, 15% after ten, and exempt after fifteen. Until the end of 2021 the exemption threshold was twenty years; ZDoh-2Z shortened it to fifteen and took the headline rate down from 27.5% at the same time.

Work through what that means for a founder with a real holding. On a €2,000,000 gain, a sale at year twelve costs €300,000 in dohodnina. The same sale at year fifteen costs nothing, and no return needs filing. Three years of patience is worth €300,000, and there is no restructuring on earth that beats waiting when the alternative is a statutory exemption you already have most of the way through.

Two details that decide real cases. First, a gift of capital to a spouse or a child can defer the tax event: the recipient inherits your acquisition date and value, so the clock is not reset and the gain crystallises only on their later disposal — with a fifteen-day notification window from the contract, curable by samoprijava under ZDavP-2 art. 63 if you miss it. Second, and in the other direction, a company buying back its own shares is taxed as a dividend at 25% on the paid-out value less acquisition cost, regardless of how long you held. A buy-back throws away the taper entirely, which surprises founders who thought of it as an elegant alternative to a sale.

None of this is an argument against Cyprus. It is an argument for sequencing: if the exit is close and the holding is old, the Slovenian rules may already be giving you the better answer on that one transaction, and the Cyprus company is about the next fifteen years rather than the last twelve.

Interest is taxed the same way, at 25%, with an annual allowance of €1,000 that ZORZFS put in place for 2024 through 2026.

Do Slovenia's CFC rules catch a Cyprus company?

Not on the standard rate, and the calculation is one line. Where it gets interesting is the exact place Cyprus is most attractive, so read the second half of this section before you build anything.

Start with where the rules actually live, because this is misreported constantly. Slovenia's controlled-foreign-company regime is at ZDDPO-2 arts. 67.h to 67.j, inserted as a new chapter by ZDDPO-2P. It is not at art. 24.a: art. 24 is the participation exemption for dividends received, an entirely different provision, and conflating the two sends people looking for rules that are not there.

A foreign entity is a nadzorovana tuja družba only if both tests are met. The control test asks whether the taxpayer, alone or with related persons, directly or indirectly holds more than 50% of the voting rights, more than 50% of the capital, or an entitlement to more than 50% of the profit, with a related person defined at 25%, in either direction, sweeping in sister entities under a common holder. The effective-tax test then asks whether the corporate tax actually paid on the entity's profit is lower than half the tax that would have been charged under ZDDPO-2.

Half of 22% is 11%. So:

That middle row is the sentence that matters. The IP Box brings the effective rate on qualifying income to 3% from tax year 2026, which is exactly the kind of position art. 67.h was calibrated to reach. And because the test measures tax actually paid on the profit rather than the rate in the statute, notional interest on new equity or a year dominated by exempt securities gains can produce the same result without the IP Box being anywhere in the picture. Anyone selling you the IP Box for a Slovenian structure without mentioning the 11% line is selling you half an answer.

Two carve-outs then decide the case, and both are real. Attribution does not apply where the entity carries on an economic activity for which it has personnel, equipment, assets and premises available — a Cyprus company with staff on the ground, a real office and decisions genuinely taken there is outside the regime on substance alone. And attribution does not apply where one third or less of the entity's income falls in the six listed passive categories, which an ordinary trading business clears without effort. What gets attributed if you are caught is the undistributed income in those categories — interest and financial-asset income, royalties and IP income, dividends and gains on participations, finance leasing, financial-sector income, and low-value-added related-party invoicing — with foreign tax credited and double counting prevented on later distribution.

One structural point worth stating plainly: arts. 67.h–67.j sit in ZDDPO-2, the corporate act, and attribute income to a taxpayer under that act. How the rules reach a holding held personally by a founder who has genuinely ceased to be a Slovenian resident is a question for a Slovenian adviser on your own facts, and we are not going to answer it in a table. The IP Box service page sets out what qualifies on the Cyprus side; whether it survives contact with art. 67.h is a Slovenian question.

Does Slovenia charge exit tax when the company moves to Cyprus?

Yes, where assets actually leave the Slovenian tax net — and no, on you personally. Those two answers get mixed up more than any other pair on this page.

The corporate charge is izstopna obdavčitev, at ZDDPO-2 arts. 54.a and 54.b, inserted by ZDDPO-2R with effect from 1 January 2020. Art. 54.a requires the taxpayer to bring its skrite rezerve — hidden reserves, being fair value less tax value at the moment of transfer — into the tax base on four triggers: a transfer of assets to its own permanent establishment abroad, a transfer from its Slovenian establishment to a seat or establishment abroad, a transfer of the business of a Slovenian establishment abroad, and a transfer of tax residence to another state. Short-term assets are excluded, and there is a twelve-month return carve-out for securities financing, collateral and liquidity management.

Read the third trigger carefully, because it carries the most useful exception in the article: assets that remain connected with a Slovenian permanent establishment stay outside the charge, since Slovenia has not lost the right to tax them. A founder who moves management and new business to Cyprus while leaving genuine Slovenian operations behind is not taxed on the assets that stay. A founder who empties the Slovenian entity is taxed on everything that leaves, at fair value, on paper profit, in the year of the move — and appreciated software, brand value embedded in transferable assets and unrealised gains on long-term holdings are exactly what that catches.

Then the softener. Art. 54.b allows the tax on those hidden reserves to be paid in up to five equal annual instalments, available where the destination is an EU member state or an EEA state with an equivalent recovery-assistance arrangement. Cyprus is an EU member state, so the deferral is available on this route as of right — one of the few places where the destination being inside the union does concrete work. The procedural conditions live in ZDavP-2 rather than in ZDDPO-2, so budget for a filing, not just a calculation.

On the personal side, Slovenia has no analogue. An individual ceasing to be resident is not deemed to dispose of their shares. Set against the countries that do mark a founder's holding to market on departure, that removes the single largest cost of leaving, and it is worth knowing before you read a comparison page that assumes every European exit works like Germany's.

How does Slovenian tax residency actually end?

By dismantling ties, in a specific order, with a filing at the end. Not by leaving. FURS's guidance is unusually explicit about this, and it is the part of the move Slovenian founders most often leave half-finished.

ZDoh-2 art. 6 sets four alternative tests, and satisfying any single one makes you a resident regardless of the others: an officially registered permanent address in Slovenia, a habitual abode there, the centre of your personal and economic interests there, or presence of more than 183 days in aggregate in the tax year, the tax year being the calendar year. The first test is purely formal, which is what makes it dangerous: nobody thinks of a registration at the upravna enota as a tax matter, and it is sufficient on its own.

Ceasing residence therefore means all of the following at once. Deregister the permanent or temporary residence. Move the habitual abode and the centre of personal interests — in practice, the family and the social life. Move the economic centre: the work, the assets, the banking. Keep the day count under the line. And then settle the status with FURS by filing the departure questionnaire, submitted through eDavki as form NF-LD, in person, by post, or by e-mail to the competent finančni urad.

Two warnings from FURS's own text deserve repeating rather than paraphrasing away. It treats an employment contract for your return to Slovenia, existing at the time of departure, as a retained tie. And it says that leaving Slovenia without establishing significant residential ties elsewhere can cause the remaining Slovenian ties to gain weight, so that you continue to be treated as a Slovenian resident. Establishing ties abroad is not decisive by itself. Dual residence in the same period is possible and is resolved by the treaty tie-breaker — but only in relation to a specific item of income, in a procedure where you claim treaty benefits, or in a mutual agreement procedure. It is not a status you can simply assert.

After departure you remain taxable on Slovenian-source income: capital income, rents and royalties. If you keep Slovenian real estate, davek od premoženja and NUSZ keep running, and a later sale brings real-estate transfer tax and capital-gains dohodnina with it.

Can a Cyprus company be dragged back into Slovenian residence?

Yes, and this is where a Slovenian founder is most exposed. It is also the risk the entire English-language corpus on relocating to Cyprus ignores, because that corpus is written from the arrival side.

ZDDPO-2 art. 5 makes a company a Slovenian resident if it has either its registered seat in Slovenia or its place of effective management — kraj dejanskega delovanja poslovodstva — in Slovenia. Either limb alone is enough, and the second limb has no incorporation defence against it. FURS's guidance on what that phrase means is specific enough to be operational: the place of effective management is where directors or senior management actually manage and run the taxpayer, meaning executing business policy and strategic decisions; it is not necessarily where supervision is exercised or where the board formally meets; and where management is exercised in one place, that place governs even if daily operations sit elsewhere.

Which means the Cyprus side has to be evidenced rather than asserted: directors physically in Cyprus, board minutes made there, a Cyprus lease and utilities in the company's name, banking operated locally, and senior people on the ground. That is also what Cyprus's own management-and-control test wants, so the two systems are pulling in the same direction for once. Where a structure genuinely needs one, our guide to nominee directors in Cyprus is honest about what a nominee does and does not solve — and against a place-of-effective-management test written like Slovenia's, it solves less than people hope.

What does the Slovenia–Cyprus treaty actually give you?

Symmetrical 5% caps, one article that decides your exit, and a pension rule that surprises people. The convention was signed in Nicosia on 12 October 2010 in Slovenian, Greek and English, with the English text prevailing, and FURS lists it as applying from 1 January 2012 and in force for 2026. It replaced the 1985 Cyprus–Yugoslavia convention. The multilateral instrument overlays it, with MLI provisions applying from 1 January 2021 for withholding taxes and 1 October 2020 for other taxes — so a principal-purpose test sits over everything below.

The withholding caps are unusually clean, and identical across the three categories:

There is no zero-rate direct-investment tier for dividends: a flat 5% ceiling whatever the holding size. In practice you may never need it. ZDDPO-2 art. 70's own domestic exemption removes the 15% withholding on outbound dividends where the recipient is resident in an EU or EEA state, is subject to income tax there, cannot credit the Slovenian tax at home, and the arrangement is not tax avoidance. Cyprus is in the EU, so a Cyprus corporate recipient can reach 0% domestically — better than the treaty's 5%, and the treaty never increases tax anyway. Anybody quoting you the 5% on dividends has quoted the worse of the two routes.

Article 13 is the one that decides a founder's exit. Immovables are taxable where they sit. Shares deriving more than half their value from immovables in the other state are taxable in that other state, so a Slovenian property-rich company stays within Slovenian reach whatever your residence. Permanent-establishment movables follow the establishment. And then the residual rule at 13(5): gains on everything else — including ordinary shares in a Slovenian trading company — are taxable only in the state of residence of the seller. A founder who has genuinely become Cyprus resident before signing a share sale is outside Slovenian taxing rights on that gain, subject to having actually ceased Slovenian residence in the sense the previous section describes, and subject to the MLI's principal-purpose test. "Genuinely" is doing all the work in that sentence.

Article 17 on pensions is quietly significant for a founder near the end of a career. Private pensions and similar remuneration for past employment are taxable only in the state of residence, subject to the government-service carve-out at art. 18(2). A ZPIZ old-age pension paid to a Cyprus resident is, on the face of the treaty, a Cyprus matter rather than a Slovenian one. Article 14 on employment income runs the standard 183-days-in-any-twelve-months triple test. And FURS records no limitation-of-benefits restriction against Cyprus, while noting that the convention applies only to the internationally recognised part of the island.

What happens to a normirani s.p. if you leave?

It closes, and the door may lock behind you for five years — or it may not, because two Slovenian government sources currently say different things. We are going to show you both rather than pick one.

First the state of the regime itself, which has been tightened twice in quick succession and is much less generous than its reputation. From 1 January 2025 the flat-rate expense allowance for a fully insured normiranec is 80% of revenue up to €60,000, and nothing at all above that, while a person not fully insured on the activity gets 80% up to €12,500, 40% from €12,500 to €30,000, and nothing above €30,000. From tax year 2026 the flat 20% rate becomes progressive: 20% up to a base of €72,000 and 35% above it for the fully insured, with the break at €33,000 for everyone else, confirmed by FURS's own notice on the 2026 changeover. If your reason for staying in Slovenia is the normiranec regime, price it again on the 2026 numbers before you decide anything — it is no longer the deal it was in 2023.

Separately from the regime, ceasing the activity ends the compulsory insurance basis. Under the EU coordination rules, where you are employed or self-employed in another member state and that state's legislation is determined to apply to all compulsory social insurance, no Slovenian insurance obligation arises from another legal relationship. Practically, once you are genuinely working from and insured in Cyprus, the Slovenian obvezno zavarovanje closes out with the s.p. or company deregistration and Cyprus becomes the competent state. The messy case — keeping a Slovenian directorship while insured in Cyprus — turns on the multi-state rules and the A1 certificate, is fact-specific, and is exactly where an unplanned Slovenian social-insurance liability tends to survive a move. Get it looked at rather than assumed.

What happens to your ZPIZ record and your pension?

It is coordinated, not forfeited, and this is one of the calmer parts of the move. Slovenia runs its own pension and disability system and the EU regulations coordinate it with the other member states' systems rather than merging them.

ZPIZ states the mechanics plainly: periods completed under different member states' insurance are aggregated to satisfy the qualifying conditions, with overlapping periods counted only once, and each country pays its proportional share of the eventual pension. What stops when you deregister is further accrual — not entitlement to what you already have. And a pension awarded in one member state can be paid in another member state where the beneficiary resides, governed domestically by ZPIZ-2 art. 120; where residence abroad is only temporary and you want payment to a foreign account, that account has to be registered with FURS on form DR-02.

What does Slovenia charge on wealth and inheritance, and does Cyprus beat it?

On aggregate wealth, neither country charges anything, so there is nothing to win. On inheritance inside the family, Slovenia is already at zero, and this is a genuine Slovenian advantage that headline-rate comparisons flatten away.

There is no net wealth tax in Slovenia. FURS's own enumeration of the taxes it administers contains no such levy — what exists are narrow asset taxes: davek od premoženja on buildings, NUSZ on building land, real-estate transfer tax, boat taxes and the motor vehicle tax. None is a charge on the stock of your net worth, so company shares, securities and cash bear no annual cost. Cyprus likewise levies no net wealth tax and no inheritance tax.

On inheritance and gift tax the Slovenian first order is exempt outright. Heirs and donees of the I. dedni red — descendants and adoptees and their descendants, the spouse, and a non-marital partner, with sons- and daughters-in-law, stepchildren and their descendants and a registered partner statutorily equated with them — are wholly exempt. Note the drafting subtlety: a surviving spouse who inherits in the second civil-law order because there are no children stays exempt for tax, since the civil order does not control the tax class. Everyone else pays on progressive scales — 5% to 14% for parents, siblings and their descendants, 8% to 17% for grandparents, aunts and uncles and their descendants, and 12% to 39% for everyone else. A gift consisting only of movables falls outside the tax below €5,000, aggregating gifts from the same donor over twelve months.

So: passing a Slovenian company down the direct family line costs nothing in transfer tax today. Passing it sideways — to siblings, cousins, or an unrelated co-founder — can reach the top of the 12% to 39% band. If your succession plan runs sideways rather than down, that is a Slovenian cost worth putting on the same page as the corporate rate.

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

Through the 60-day rule in most cases, and yes — Slovenian citizenship is EU citizenship, so the Yellow Slip route is open to you.

The simple route is more than 183 days physically in Cyprus in the calendar year. The 60-day route asks for far fewer days and considerably more commitment on the ground, and it became easier in 2026, because the old condition about not being tax resident anywhere else 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 throughout the year; and a permanent home in Cyprus you own or rent.

For a Slovenian founder there is a specific trap folded into that improvement. Dropping the fifth condition makes Cypriot residence easier to acquire; it does absolutely nothing to end the Slovenian one, and ZDoh-2 art. 6 keeps running in the background on its own four tests. Acquiring Cyprus residence and ending Slovenian residence are two separate projects with two separate paper trails, and only the second stops the 25% final tax on your dividends. Conveniently, the same facts serve both: a directorship of your own Cyprus company is the office the third condition asks for, and the Cypriot lease satisfying the fourth is also evidence that your centre of interests has moved.

The Yellow Slip records your residence under EU free-movement rules. It says where you live; it says nothing about how you are taxed, and our guide separates the two while Sumly files the application. Tax residency and non-dom registration is a different step again, at €750 per person, with the day counting set out in the 60-day rule guide and the seventeen-year exemption in Cyprus non-dom status.

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 Slovenian founder?

Short, which after the previous seven sections is the point. One corporate rate with no bands and no regime to elect, one relief that changes the arithmetic, and a shareholder layer that is nearly empty.

The company pays 15% on taxable profit from tax year 2026. Qualifying intellectual property is taxed at an effective 3% under the IP Box, subject to everything the CFC section said about the 11% line. Distribution then costs a non-dom shareholder nothing in Special Defence Contribution for seventeen years and nothing in personal income tax, leaving GeSY capped at €4,770 a year. Compulsory VAT registration begins at €15,600 of taxable turnover, with standard-rated supplies at 19% — the same standard rate you are used to at home, which makes the VAT half of the move unusually undramatic. There is no net wealth tax and no inheritance tax. The wider picture is in Cyprus tax benefits for foreigners and what changed in the 2026 reform; the mechanics of incorporation are in how to register a company in Cyprus and what it costs.

Can a Slovenian e-commerce brand run through Cyprus?

Yes, and the honest framing is operational rather than about market access. Slovenia and Cyprus are both inside the single market and both use the euro, so nothing is being unlocked that you did not already have. What changes is where the qualifying income is taxed and how much of the compliance runs itself.

The Cyprus company gets an EU VAT number verifiable in VIES, zero-rating on intra-EU business sales where the usual conditions are met, and one-stop-shop reporting for consumer sales across the bloc. None of that is visible to your customers in Ljubljana or Munich.

What actually breaks a store's books is volume. A few thousand small orders a month across currencies and payment processors, each with a VAT treatment depending on who bought and where they were, and then fees, refunds and payouts that never line up with the sales behind them. The Shopify and WooCommerce plugins take that firehose and post it, order by order, with the right Cyprus VAT code already on it — which turns the quarterly return from a reconstruction exercise into something that has been accumulating quietly since the first of the quarter. The VAT feature shows it accumulating as the quarter runs, and the AI does the booking.

Two worked examples

A consultancy distributing €200,000 of profit. In Slovenia the company pays 22% — €44,000 — and the €156,000 distributed carries 25% final tax, another €39,000, leaving €117,000 in hand. Through Cyprus the company pays 15%, or €30,000, and a non-dom founder distributing the remaining €170,000 pays GeSY at 2.65%, about €4,505, keeping roughly €165,495. That is a gap of about €48,500 on identical facts, repeating annually. It is also the profile where the residence sections above matter most, because the entire gap disappears if the company is still Slovenian resident under art. 5 or you are still a Slovenian resident under ZDoh-2 art. 6.

A software company with €400,000 of qualifying IP income. In Slovenia: €88,000 of DDPO at 22%, then €78,000 of final tax on the €312,000 distributed, leaving €234,000. In Cyprus, income qualifying under the IP Box bears an effective 3% — €12,000 — and the health contribution is capped at €4,770 however much is distributed, leaving roughly €383,230. A difference of about €149,000 in one year, growing with the income. And this is precisely the profile where every warning on this page fires at once: 3% is under the 11% half-tax line, so the case rests entirely on the substance carve-out at art. 67.i(2) and the one-third passive-income test at art. 67.i(3), on the shares being held in a way that keeps arts. 67.h–67.j out of the picture, and on your own Slovenian residence having genuinely ended.

Both examples assume full distribution and headline rates, and neither prices the cost of running real substance in Cyprus — which, given everything the CFC and residence sections say, is not an optional line. Your own facts change the answer, which is what a 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?

A shape rather than a schedule. The Slovenian half has no single hard deadline forcing your hand, which is easier in one way and considerably more dangerous in another: nothing makes you finish it.

• Before anything moves — and we will raise this before you commit. We count your holding period with you. If you are inside three years of the fifteen-year exemption, we model waiting before we model leaving, and we will say so even though it delays the sale. We put the art. 67.h question to a Slovenian adviser from our network against your intended Cyprus profile, and they model art. 54.a if assets are actually going to move.
• Month 1. We form the Cyprus company, with books open the day you order, and start the Yellow Slip. You sign a Cypriot lease in your own name. Your Slovenian adviser begins the deregistration of your stalno prebivališče at the upravna enota — the slowest item and the one everyone leaves last, which is why we put it first.
• Months 1–3. We complete the Cyprus VAT registration and, where they apply, the social insurance, employee and UBO registrations, and get banking and EU payments working. You take up the directorship and hold the decisions physically in Cyprus; we minute them, for both the Cypriot management-and-control test and the Slovenian art. 5 one.
• Months 3–9. You live there, and we accumulate the evidence with you: days, utility accounts, Cypriot social insurance, the family's move. Your adviser files the NF-LD departure questionnaire with FURS once the ties are genuinely cut, not before.
• After the first full year. We apply for the Cyprus tax residency certificate and register your non-dom status. Until Slovenian residence has actually ended, dividends still bear the 25% Slovenian final tax, and we will keep treating them that way rather than letting you assume otherwise.

What mistakes do Slovenian founders actually make?

Five, and the first three cost the most.

Running the Cyprus company from Slovenia by videocall and assuming incorporation settles residence — when FURS's guidance says in terms that remote management pushes the place of effective management to where the business is actually run. Building the plan on the IP Box without checking the 11% half-tax line and the two carve-outs that decide whether art. 67.h attributes anything. And selling a long-held Slovenian holding at year twelve or thirteen because the move created momentum, when three more years of holding would have made the gain exempt outright.

Then two quieter ones. Leaving the registered stalno prebivališče in place and staying a Slovenian tax resident on the strength of a single formal test, while believing the day count has settled the question. And dismantling a normirani s.p. as part of the move without resolving the five-year re-entry contradiction first — a decision that is trivial to make and, on FURS's reading, expensive to reverse.

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 Slovenian founders take the first. Self-service means the Registrar's forms and fees, a registered office you arrange, VAT and VIES registration, provisional tax twice a year, annual statements and books your auditor will accept — stacked on top of a cross-border move you are already running with two tax authorities watching. The Sumly route replaces that with three published prices: formation from €950 one-time, the software from €39 a month, and a Sumly certified bookkeeper at €390 a month, with books open the day you order and every return prepared box by box.

The software alone runs and operates the company from Cyprus or from Slovenia: invoicing, AI double-entry bookkeeping, live open-banking feeds, all VAT, VIES, provisional and corporate returns prepared box by box, live reports, a document inbox with its own e-mail 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.

Everything on this list is offered to everyone: a virtual address with PO box and digital mail scanning forwarded wherever you are; nominee director and secretary where the structure calls for them; the Yellow Slip, which your EU citizenship makes available; tax residency and non-dom at €750 per person; and every registration — VAT, social insurance, employees, UBO — done properly the first time.

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

That division of labour matters more than usual for a Slovenian founder, because the hardest questions on this page — how art. 67.h applies to your intended Cyprus profile, how much of the art. 54.a charge your move actually triggers, and whether the normiranci door really is shut for five years — are Slovenian questions that need Slovenian answers. The Cypriot half, by contrast, is a single provider with a single dashboard and four prices printed on the site. That is what makes Sumly the best choice for Slovenian founders creating a company in Cyprus and relocating their business to it.

Why do people choose Cyprus over other tax havens?

Because it is somewhere you would live even if the tax were ordinary, which is not true of most of the alternatives on the list. For a Slovenian founder — already in the EU, already in the euro, already living somewhere pleasant — that part of the argument has to carry real weight, because the market-access argument carries none.

Violent crime is among the lowest in the European Union. The island works in English in practice: business, banking, contracts, professional services and most official dealings, which for anyone already trading internationally is a change of working language rather than of culture. People from everywhere are already here, so nobody is the only foreigner in the room. Business and real estate are both booming. Officialdom is open to people who want to trade rather than treating trade as something to be licensed first. Groceries — meat, fruit, vegetables — are affordable. And the coast: a Cyprus winter still leaves you an afternoon at the beach, and the summers are what people cross continents to book.

The Slovenian push list is specific, and short enough that we are not going to pad it. Twenty-two per cent on retained profit for 2026 through 2028 against fifteen. A combined 41.5% on distributed profit against a Cyprus position where the shareholder layer is a capped health levy. A dohodnina scale reaching 50% with over 40% of contributions on top of it, split across both halves that a founder pays out of the same business — which makes paying yourself a real salary in Slovenia one of the most expensive things you can do in the EU. A place-of-effective-management test that FURS has drafted its guidance around aggressively. A residence test where a single formal registration keeps you inside. And a flat-rate regime for smaller operators that has been narrowed twice in two years and now carries a re-entry bar that two government sources describe differently.

Against that, be fair to Slovenia, because a page that was not would be lying to you. No exit tax on you personally. No net wealth tax. Nothing at all on passing the company to your children. And a capital-gains taper that ends in outright exemption — which, if your horizon is long and your holding is old, may simply be the better answer, and we would rather say so than sell you a move that does not pay for itself.

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

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

Two Cyprus-built products will come up in your research, 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: best support, best bookkeeping software, best AI for bookkeeping, best bookkeeper, best prices, and the whole thing easy to run. We publish the comparisons rather than just asserting them: Sumly vs Cybooks, Sumly vs Balabook, and for the international tools Xero, QuickBooks and Sage.

One line about the IP Box is worth repeating, and for a Slovenian founder it arrives with the 11% caveat attached rather than as a headline: 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 begins as a conversation rather than a form, which is one more argument for putting the meeting at the front. The IP Box feature shows how the tracking works day to day.

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 Slovenian founders actually ask

Frequently asked

Is Slovenian corporate tax 19% or 22%?

Both answers are printed in official texts, which is why the question keeps coming back. ZDDPO-2 art. 60 still reads 19%, and it has never been amended. The rate you actually pay is 22%, set by art. 64 of ZORZFS — the post-flood reconstruction act — for the tax years 2024 through 2028 inclusive. It is a rate override, not a surcharge bolted on top: one tax, computed once, on the ordinary ZDDPO-2 base. Only the destination of the three-point difference changes, because it is earmarked for the reconstruction fund. Searching for a 'ZDDPO-2T' amendment finds nothing because none exists.

Does the 22% rate really fall back to 19% in 2029?

On the current text, yes — ZORZFS art. 64 names five years and no more, so tax year 2029 reverts to ZDDPO-2 art. 60 by operation of law without anyone having to legislate for it. We found no act extending it. But note what that sentence does and does not promise. A temporary rate that has been legislated once can be extended by a single line in a later act, and the reversion is a default position rather than a right you hold. If your plan only works because 2029 is 19%, the plan has a legislative risk in it.

Do Slovenia's CFC rules catch a Cyprus company?

Not on the headline rate, and the arithmetic is easy to check. ZDDPO-2 art. 67.h requires control above 50% and tax actually paid below half of what Slovenia would have charged — at 22%, that line sits at 11%. Cyprus at 15% is clear of it. What is not clear of it is any Cyprus position that drives the tax actually paid on the profit below 11%: the IP Box, notional interest, or a profit mostly made up of exempt securities gains. The test is on tax paid, not on the rate in the statute. Two carve-outs then matter: real economic substance in Cyprus, and a passive-income share of one third or less.

Will Slovenia charge exit tax when I move the company to Cyprus?

If assets leave the Slovenian tax net, yes. ZDDPO-2 art. 54.a brings hidden reserves — fair value less tax value — into the tax base on a transfer of tax residence abroad, among other triggers, and taxes them at the ordinary rate. Assets that stay connected with a Slovenian permanent establishment are outside it, which is the single most useful sentence in the article for a founder who is not abandoning Slovenia entirely. Art. 54.b then allows payment in up to five equal annual instalments where the destination is an EU member state, and Cyprus is one.

Is there an exit tax on me personally when I leave Slovenia?

No equivalent to the corporate charge exists for individuals. Slovenia does not treat an emigrating individual as having disposed of their shares on the day they cease to be resident, so your own holding is not marked to market on the way out. That is a genuinely favourable feature and it is easy to miss when you are reading about the corporate article. The corporate charge is about the company's assets migrating; it is not about your shareholding.

How do I actually stop being a Slovenian tax resident?

By breaking every significant tie, not by boarding a plane. ZDoh-2 art. 6 has four alternative tests and any single one makes you resident: a registered permanent address in Slovenia, habitual abode, the centre of your personal and economic interests, or more than 183 days in the calendar year. So you deregister the residence with the administrative unit, move the family and the economic centre, keep the day count down, and then settle status with FURS — the departure questionnaire, filed through eDavki as form NF-LD. FURS also warns that leaving without establishing real ties somewhere else lets the remaining Slovenian ones gain weight.

Can a Cyprus company be pulled back into Slovenian tax residence?

Yes, and FURS's own guidance describes exactly how. ZDDPO-2 art. 5 makes a company Slovenian resident if it has either its seat or its place of effective management in Slovenia — either limb alone is enough. FURS then says that where management is not exercised in one place, and directors run the company remotely by telephone, internet or video conference, the place of effective management is where the business is actually run day to day. A Cyprus company directed by videocall from Slovenia is the case that guidance was written for.

Should I sell my Slovenian company before I move, or after?

It depends almost entirely on how long you have held it, and the Slovenian taper is generous enough that the answer is often 'neither yet'. Dohodnina on capital gains is 25%, falling to 20% after five completed years, 15% after ten, and to nothing at all after fifteen. If you are twelve years in, three more years of patience is worth more than any structure. Separately, art. 13(5) of the Slovenia–Cyprus convention gives the taxing right on gains from ordinary shares to the state where the seller is resident — so a genuine change of residence before signing matters, subject to the treaty's principal-purpose test.

What happens to my normirani s.p. if I close it and later want it back?

This is the one point on the page where two official Slovenian sources disagree, so we are not going to pick a side for you. FURS's own activity-income brochure, in its April 2026 edition and citing ZPZR-A, still sets out a five-tax-year bar on re-entering the flat-rate regime after exit or cessation, with worked examples. SPOT, the government business portal, states that ZPZR-A removed that prohibition. Both are government sources. Get the answer in writing from FURS before you dismantle an s.p. you might want back.

Keep reading

• Every country's route to Cyprus — the departure guide for wherever you are now
• Cyprus non-dom status — the seventeen-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
• Cyprus tax benefits for foreigners — the whole picture in one place
• What changed in the 2026 Cyprus tax reform
• How to register a company in Cyprus and what it costs

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. Slovenian figures are stated for 2026 and cited to FURS, Uradni list RS and ZPIZ; the 41.5% combined burden on distributed profit is arithmetic derived from the published 22% and 25% rates rather than a figure FURS prints, and the normiranci re-entry bar is left unresolved because two official sources conflict. 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.