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

For a founder in Ukraine the first question is not what Cyprus charges. It is whether the money can legally move at all — and under the currency regime now in force, ordinary outbound investment has no permitted channel, while dividends out of a Ukrainian company run through a monthly ceiling with four conditions attached. Get that order right and the rest of the plan follows.

Updated for 2026 Cyprus tax law and regulations.

Moving from Ukraine to Cyprus with one provider instead of five

Sumly is the fully digitalized, one-stop way to relocate a Ukrainian business to Cyprus, register the company and operate it from the day it exists. We register the company, open your books the day you order, prepare every Cyprus return box by box, and run the tax residency and non-dom application as a fixed-price service. One dashboard, one provider, one price list stated upfront — rather than a law firm for the registration, a bookkeeper for the ledgers, and nobody for everything in between.

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.

Can you legally move money out of Ukraine to fund a Cyprus company?

Not through a Ukrainian bank as a direct investment, on the current text. This is the first thing to establish, because every other part of the plan sits downstream of it, and because it is the question the destination-side pages simply do not answer.

Ukraine's banking and foreign-exchange regime during martial law is set by a single instrument: National Bank Board Resolution No. 18 of 24 February 2022, currently in the version of 11 August 2026. Its architecture is the opposite of what most founders assume. Paragraph 14 begins by prohibiting authorised institutions from making cross-border transfers of currency values out of Ukraine, and from crediting the correspondent accounts of non-resident banks, and then lists the cases in which it is nonetheless permitted. That enumerated list has grown to dozens of numbered exceptions. Anything not on it cannot leave through the banking system.

Read the whole of that list and there is no exception permitting a resident to transfer funds abroad in order to subscribe for shares in, or capitalise, a foreign company. The provisions that do use the word investment run the other way: the National Bank operates an investment limit measured by foreign currency brought into Ukraine into a resident's charter capital since 12 May 2025, which earns a company outbound headroom for other purposes. The National Bank's own description of the mechanism lists those purposes as dividend repatriation, closing old import contracts, returning prepayments, repaying old external loans and financing foreign representative offices. Capitalising a new foreign subsidiary is not among them.

So the practical routes are narrower than the marketing suggests, and worth naming plainly: capitalising the Cyprus company from funds already held outside Ukraine; using an individual's personal monthly allowances, which are far too small for anything beyond nominal capital; or obtaining a specific National Bank permission. This is a reading of the published text rather than advice on your file, and it is exactly the point at which a Ukrainian adviser earns their fee.

How much can a Ukrainian company actually repatriate in dividends?

One million euro a calendar month, and only if four separate conditions are all satisfied. This channel — subparagraph 46 of that same paragraph 14 — is the one that matters to a founder who moves the shareholding but leaves the operating company in Ukraine.

The permission allows a resident issuer to transfer foreign currency abroad to a foreign investor to pay dividends, subject to the following:

The last two are anti-abuse rules and they defeat a specific plan people arrive with. Inserting a Cyprus holding company in order to release an accumulated dividend does not work: the six-month clock restarts when the new shareholder acquires the rights, and a freshly registered Ukrainian entity has no route out for a year. The first condition is the one that surprises founders with long histories — profits accumulated before 2023 stay where they are.

What can a Ukrainian individual move abroad each month?

Enough to live on and nowhere near enough to fund a company. The personal limits were raised on 11 August 2026, and the direction of travel is loosening rather than tightening, but the ceilings remain low in absolute terms:

At the official hryvnia rate those hryvnia ceilings translate into a few thousand euro a month for ordinary outbound spending. That is the whole argument for a company banking inside the European Union, and it is a stronger argument than any rate comparison in this guide. The National Bank's August 2026 package raised several of these limits at once — non-cash currency purchase, cash withdrawal from currency accounts, hryvnia spending abroad and corporate card spending — which tells you the position is being relaxed deliberately, not that the constraint has gone.

Is Cyprus actually cheaper than what a Ukrainian founder pays now?

On the corporate line, for most of the founders reading this, no. Saying otherwise is the fastest way to lose a reader who knows their own tax bill, so here is the honest comparison first.

Ukraine's base corporate profit tax rate is 18%. Almost no Ukrainian technology founder pays it. Two regimes sit underneath:

A Diia City company that reinvests pays no entity-level tax until it distributes, and where it has not paid dividends for two consecutive calendar years the receiving individual's dividend is excluded from taxable income entirely. Entry is not free — the regime requires an average monthly remuneration of at least the equivalent of EUR 1,200, an average headcount of at least nine, and qualified income of at least 90% of total income — but for a funded product company it is genuinely competitive, and a Cyprus company at 15% does not beat it.

Single tax group 3 is a turnover tax rather than a profit tax, so the comparison depends entirely on margin: 6% all-in on revenue against 15% on profit favours Ukraine at high margins and Cyprus at low ones. It also has a ceiling. The group 3 income cap is 1,167 minimum wages a year, and with the 2026 minimum wage set at UAH 8,647 that arithmetic gives roughly UAH 10.1 million — a few hundred thousand euro. Above the cap, income is taxed at 15% and the regime stops being the answer.

So the real case for Cyprus is not the rate. It is currency freedom, euro banking and payment rails that do not run through a monthly ceiling, an EU VAT number your European customers can verify, a regime that is not written in transitional provisions, and — for a founder who genuinely relocates — the non-dom position described further down. Anyone selling you Cyprus on a rate comparison against Diia City is selling you arithmetic that does not work.

What is the military levy in 2026, and when does it actually end?

Five percent, and not for a while. Two facts here are the ones most published content still gets wrong, and both are checkable in a single provision.

The levy sits in the transitional provisions of the Tax Code rather than its main body. It was raised from 1.5% to 5% for individuals generally, and single tax group 3 payers pay 1% of income instead. Content still quoting 1.5% for an employee or a founder's salary is describing the position before October 2024.

The second fact is about duration. The reversion to 1.5% is not tied to the end of martial law but to a date several years beyond it: the Code, as amended by Law No. 4835-IX of 7 April 2026, restores the lower rate only from 1 January of the year following the third calendar year after the year in which martial law is terminated or cancelled. A founder modelling a five-year plan should budget 5%, not a temporary surcharge.

What does a dividend from a Cyprus company cost while you still live in Ukraine?

Fourteen percent, and this is the single number that decides whether moving the company without moving yourself is worth doing. It is also the number almost no competing page states.

The Tax Code taxes dividends by reference to who paid them. A dividend from a Ukrainian company that is itself a corporate income tax payer carries 5% personal income tax. A dividend from a non-resident company — a Cyprus limited among them — is charged at half the general 18% rate, that is 9%. Add the 5% military levy and a Ukrainian tax resident receiving a Cyprus dividend keeps 86 cents in the euro before anything Cyprus charges. There is no reduced rate below that for foreign dividends.

Which sets up the honest framing for the whole decision. Moving the company alone converts a Cyprus 15% corporate charge into 15% plus 14% on the way home. Moving yourself as well is what makes the structure work — and that is a residency question, covered below, not a company question.

Do Ukrainian CFC rules catch a Cyprus company?

Frequently yes on the reporting side, and often no on the tax side — and confusing those two is where founders get hurt. The controlled foreign company regime in article 39-2 has been in force since 2022 and it is the largest compliance exposure in this corridor.

You are a controlling person if you hold more than 50% of a foreign company; or more than 10% where Ukrainian residents together hold 50% or more; or if you exercise de facto control regardless of formal holdings. Indirect holdings through a chain are multiplied and holdings through several chains are added together, and a share includes any right to influence votes, receive profit, block a distribution or take assets on liquidation — so a veto in a shareholders' agreement can create control without equity. Note also that the 25% threshold quoted in a great deal of 2022–2023 Ukrainian content was transitional; from the 2024 reporting year the permanent limb is more than 10%.

Then the exemptions, which matter more than the definitions. Adjusted CFC profit escapes tax in the controlling person's hands if there is a double tax or information exchange treaty with the CFC's jurisdiction and either the company actually pays profit tax at an effective rate no lower than Ukraine's base rate less five percentage points, or its passive income is not more than half its total income. The treaty limb is satisfied for Cyprus. The effective-rate limb is arithmetic off the Ukrainian rate: 18% minus five points gives a floor of 13%, measured as tax expense divided by pre-tax accounting profit from the financial statements, multiplied by 100.

That definition is where a Cyprus structure can quietly fail a test it looks like it passes. A Cyprus company on the plain corporate rate clears 13% comfortably. A Cyprus company whose income is largely qualifying intellectual property, taxed at an effective 3% from tax year 2026 under the IP Box, does not — because the test measures tax actually borne, not the headline rate. It then falls back on the passive-income limb, or on the de minimis.

For most founder-scale companies the de minimis is what actually applies: the exemption bites where the total aggregate income of all of one controlling person's CFCs, from all sources, does not exceed the equivalent of EUR 2,000,000 at the end of the reporting period. Note that it is measured per person and aggregated across every CFC they control, not per company.

One more rescue rule is worth knowing, because it is why a real Cyprus operation behaves differently from a shell. Even where passive income exceeds half the total, it is treated as active if the company genuinely performs substantive functions, bears the risks and uses the assets, and has the resources to do so — qualified staff, fixed assets owned or used, adequate own capital. Substance is not decoration in this regime; it is the test.

If the CFC profit is charged, the rate depends on timing. Undistributed adjusted profit attributed to an individual is taxed at 18% plus the levy, while profit distributed before the CFC report is filed and actually received is taxed at 9% plus the levy. Distributing before you file halves the charge. That is a planning point you can read off the statute.

Are Ukrainian CFC penalties really deferred until after the war?

No — and correcting this is probably the most valuable paragraph on the page, because the opposite is asserted repeatedly in Ukrainian-language search results.

Two provisions get mixed together. The first is a genuine holiday, and it is narrow: penalties for breaching article 39-2 in determining and computing CFC profit do not apply for the 2022 and 2023 reporting years. It expired with 2023 and it never covered the filing obligation itself. The second is the wartime suspension of statutory time limits, which ran only until 1 August 2023 — and which expressly excluded the submission of reporting and documents, including those provided for by articles 39 and 39-2. CFC reporting deadlines were never suspended at all.

When is the CFC report due, and what has to be filed within 60 days?

Two separate clocks, and the short one starts on the day the Cyprus company is incorporated. Founders discover the annual report and miss the notification.

The annual report is filed together with your yearly return, electronically, with duly certified copies of the CFC's financial statements attached. An individual controlling person files it with the annual property and income declaration by 1 May of the year following the reporting year; a corporate controlling person files with the profit tax return within 60 calendar days after the last day of the reporting year.

There is a safety valve that very few people use. Where the controlling person cannot obtain the financial statements or compute adjusted profit in time, article 39-2.5.4 permits a short-form report carrying only the company's identifying details, the size of the holding and the ownership structure, with the full report due by the end of the following calendar year and a clarifying return if income turns out higher — and the Code states that penalties and interest do not apply in that case.

Note the distinction that catches careful people: the exemptions in article 39-2.4 are exemptions from taxation of the adjusted profit, not from filing. The report itself is where you state the grounds on which the exemption is claimed, so an exempt company is still a reporting company.

Can Ukraine treat your Cyprus company as a Ukrainian taxpayer?

Yes, and the provision that does it is broader than the international norm. This — not the CFC regime — is what turns a Cyprus company into an 18% Ukrainian taxpayer, and it is almost entirely absent from published content in both languages.

Article 133.1.5 makes corporate income tax payers of foreign companies that have their place of effective management in Ukraine. Ukraine is that place if any one of three things holds: meetings of the executive body are held in Ukraine more often than in any other country; management decisions and current operational activity are predominantly carried out from Ukraine by its officers; or actual management is predominantly carried out from Ukraine regardless of whether the people doing it hold any formal office at all.

Then comes the tie-breaker, and it is the part to read twice. Where the company might also be found to have its place of effective management in another foreign state, Ukraine is designated the place of management if any one of the following is performed in Ukraine: managing the foreign company's bank accounts, keeping its accounting or management accounts, or managing its personnel.

Read plainly: a Cyprus company with genuine Cypriot directors, real board meetings and a Cyprus office can still be pulled into Ukrainian corporate residency because its online banking is operated from Kyiv, or its bookkeeping is done there, or its HR is run from there. Any single limb is sufficient. The founder who forms in Cyprus but keeps the accountant, the payroll and the bank logins at home has not moved the company — they have created one with two tax residencies and a domestic statute pointing at the wrong one.

What this means in practice is unglamorous and specific. The bookkeeping has to be done on the Cyprus side, on a Cyprus system, by people who are not sitting in Ukraine. Bank mandates and payment approvals have to belong to Cyprus. Staff management has to sit where the company sits. That is a large part of what Sumly does day to day, and it is worth stating that it is a compliance function rather than a convenience. Our note on nominee directors in Cyprus sets out where a nominee helps with this and, more usefully, where it does not.

The same article also gives a foreign company the right to register voluntarily as a Ukrainian tax resident, effective from 1 January of the year in which the application is filed. The mechanism is live, which tells you the provision is not a dead letter.

When does Ukrainian tax residency actually end?

Factually, and without a procedure — which is harder to manage than a procedure would be. The test in article 14.1.213 runs as a strict cascade: place of residence in Ukraine; then, if you are resident in two states, place of permanent residence; then the state of closer personal or economic ties, the centre of vital interests; then presence in Ukraine of not less than 183 days in the tax year; and finally, if nothing else resolves it, Ukrainian citizenship decides.

Two sentences inside that provision do most of the work and are almost never quoted. The first is a presumption: a sufficient, though not exclusive, condition for locating the centre of vital interests in Ukraine is the place of permanent residence of the person's family members, or their registration as a business entity. Family staying behind, or an open ФОП registration, is by itself a statutory ground to treat you as still Ukrainian. The second is that self-declaration only runs one way: the Code provides a mechanism by which a person declares themselves in, not one by which they declare themselves out.

Search the consolidated Code for a procedure by which an individual ceases to be a Ukrainian tax resident and there is none. No deregistration filing, no exit ruling, no certificate of non-residence. Residency simply stops being satisfied on the facts, which means status is resolved retrospectively — in a dispute, on the evidence, years later. Build the file as you go.

The closest thing to a formal departure step is a compliance obligation with an awkward clock. A resident leaving for permanent residence abroad must file a tax declaration no later than 60 calendar days preceding departure, after which the authority has 30 days to verify the liability and issue a certificate of payment and of the absence of tax liabilities, which is presented to the customs authorities. Anyone who leaves first and plans afterwards has already missed it.

Does Ukraine charge an exit tax?

No. There is no deemed disposal on ceasing residence, no charge on moving assets or a seat abroad, and no clawback of previously untaxed gains. The basis is structural rather than a single provision: the Code sets a closed list of national taxes — profit tax, personal income tax, VAT, excise, environmental tax, rent payment and customs duty — a closed list of local taxes and levies, and then provides that the establishment of national taxes and levies not provided for by this Code is prohibited. Nothing in either list resembles a departure charge.

The same closed lists dispose of another question. Ukraine levies no net wealth tax. What exists is a local property tax with real-estate, high-value-vehicle and land components — charges on specific assets, not on net worth.

What happens to inheritance and gifts once you are non-resident?

This is the one departure trap in Ukrainian law that has nothing to do with companies, and it is genuinely expensive. Inheritance between family members of the first and second degree of kinship is taxed at 0%, and gifts between individuals run on the same scale, because the Code taxes objects of gift received from another individual under the rules established for inheritance.

But that zero rate is conditioned on residence on both sides. Where the deceased is a non-resident, or the heir is a non-resident inheriting from a Ukrainian resident, any asset is taxed at 18%. A founder who successfully ceases Ukrainian residency and later inherits from a parent still in Ukraine moves from nothing to eighteen percent on the whole estate. Note also that a gift from a company or a self-employed person is taxed as a fringe benefit at 18% rather than on the inheritance scale, which closes the obvious workaround. This belongs in the family conversation before the departure date is fixed, and it is worth Ukrainian advice rather than a rule of thumb.

What do the Ukraine–Cyprus treaty rates really say in 2026?

Dividends at 5% or 10%, interest at 5% — and the reason most published content says otherwise is a documentation quirk you can verify in thirty seconds.

The Convention was signed on 8 November 2012. A Protocol was done at Kyiv on 11 December 2015, ratified by Law No. 243-IX of 30 October 2019, and entered into force for Ukraine on 28 November 2019. The legislature publishes the two as separate documents and does not consolidate the Protocol into the Convention text: the Convention page still displays the 2012 originals and carries only a cross-reference note pointing at the Protocol. Read the Convention URL alone and you will publish pre-2020 rates, which is exactly what a good deal of the market has done.

Look closely at the two limbs of the 5% dividend rate. The 2012 original required 20% of the capital or an investment of EUR 100,000; the Protocol replaced it with an and. Content describing it as an either/or is describing the rule that stopped applying in 2020, and a holding built to satisfy only one limb does not get 5%.

On capital gains, the Protocol replaced article 13 outright. Gains on shares deriving more than half their value directly or indirectly from immovable property in the other state may be taxed there — with carve-outs that matter to an operating business. The rule does not apply to shares quoted on a recognised exchange, to alienations in the course of a corporate reorganisation, to an open joint-stock company, to similar interests in real-estate funds, or where the immovable property from which the shares derive their value is property in which business activity is carried on. That last carve-out takes an operating company that happens to own its own premises out of the real-estate-rich rule entirely. And the residual paragraph now taxes other gains only in the alienator's state of residence provided that they are subject to tax there — a proviso the 2012 text did not contain.

One caution on all of it. Treaty relief turns on beneficial ownership and on the anti-abuse rules applicable to the arrangement, not only on the rate table, so treat these figures as the ceiling a properly constituted holding can reach rather than as an entitlement. That is a question for a Ukrainian adviser on your facts.

What happens to your existing ТОВ or ФОП?

Nothing automatic, and that is the problem — the defaults are all mildly unfavourable. Nothing in the Code forces a Ukrainian company to be wound up when its owner leaves, and there is no charge on the change of shareholder residence as such. Three things do change.

Withholding on the way out. Once the shareholder is a non-resident, dividends and other Ukraine-source income attract 15% withholding unless an international treaty provides otherwise. For a Cyprus corporate shareholder the treaty brings that to 5% or 10% as set out above, on beneficial-ownership evidence and a Cypriot certificate of residence.

Actually receiving it. The binding constraint is not the rate but the currency channel: the monthly ceiling, the 2023-profits restriction, the twelve-month issuer age and the six-month holding period from the section above. Plan distributions against the calendar, not against the tax return.

The ФОП. Keeping it open is affirmatively harmful, for the residency reason set out above. Closing it is part of the departure, not an afterthought.

There is one genuine, checkable advantage of Cyprus over the offshore alternatives a Ukrainian founder gets pitched. The Cabinet of Ministers maintains the list of jurisdictions whose transactions are treated as controlled on jurisdiction grounds for transfer pricing. In the version in force from 1 January 2025, that list runs to 46 jurisdictions and Cyprus is not among them. Transactions between a Ukrainian company and a Cyprus company are therefore not controlled transactions on that basis. The same cannot be said of the BVI or Belize, and it is the sort of difference that only shows up when the audit does.

One live question we will not answer for you, because it is genuinely unsettled: whether a group 3 ФОП may lawfully continue on 5% for foreign-source income while physically living abroad. The rates and thresholds are clear; the interaction with residence and permanent establishment is contested in practice and depends on facts. Ask a Ukrainian adviser rather than a forum, and get the answer before you rely on it.

What about ЄСВ and your pension?

The unified social contribution is 22% of the base, with a floor at the minimum wage where the base falls below it, and it is expressly not part of the tax system. Its ceiling changed for 2026: the standing definition of the maximum base was suspended and the Budget Law set it at 20 minimum wages.

The change most content has missed concerns sole traders. The wartime rule that allowed a ФОП and independent professionals not to charge or pay the contribution for themselves has been suspended for 2025 and again for 2026. A ФОП pays ЄСВ in 2026. Any guide still describing it as voluntary during martial law is two years out of date.

On pensions we will be honest about the limits of what we checked. Ukraine's solidarity pension is built on insured periods, so a founder who stops paying the contribution stops accruing entitlement — that is how the system is designed rather than a figure we can cite. Whether accrued Ukrainian entitlement travels, and whether any social security coordination exists between Ukraine and Cyprus, we did not verify from an official source and therefore do not assert. Ask the Ukrainian pension authority directly before you assume either way; it is a short question with a long half-life.

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 Ukrainian founder?

Flat, and above all predictable — which is the actual product. A Cyprus limited company pays 15% from tax year 2026 on taxable profit: one rate, no bands, the same on €60,000 as on €6 million. Qualifying intellectual property can bring the effective rate on that income to 3% from tax year 2026 under the IP Box — with the CFC consequence flagged earlier, which is a reason to design the two together rather than in sequence.

Then the owner takes the money out, and the gap opens. A Cyprus tax resident who is not domiciled in Cyprus — the position nearly every relocating founder qualifies for — pays no Special Defence Contribution on dividends for 17 years of Cyprus residence, and dividends fall outside personal income tax altogether. What remains is the health contribution at 2.65% on income up to €180,000 a year — a maximum of €4,770 whatever you distribute. Cyprus levies no net wealth tax and no inheritance tax.

Salary is taxed on a progressive scale running from 0% to €22,000 rising to 35% above €72,000, and the VAT position is straightforward: registration is required from €15,600 of taxable turnover, at a standard rate of 19%. The detail is in Cyprus non-dom status and Cyprus tax benefits for foreigners.

How does a Ukrainian founder become Cyprus tax resident?

Usually through the 60-day rule, which 2026 made materially easier to satisfy. The well-known route is spending more than 183 days a year on the island. The shorter one trades days for commitments you have to hold all year.

From tax year 2026 the rule has four conditions, the old fifth having been removed from the 60-day rule: 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 maintained through the year; and a permanent home in Cyprus owned or rented. The condition that went — not being tax resident anywhere else — was the awkward one, because another state's claim no longer disqualifies you by itself. Competing claims resolve under the treaty, whose tie-breaker for individuals follows the familiar order of permanent home, centre of vital interests, habitual abode, nationality and then mutual agreement.

For a Ukrainian founder the third condition is usually satisfied by a directorship of your own Cyprus company, which is why forming the company and establishing residency is one project rather than two. On immigration, one clarification that saves disappointment: the Yellow Slip is a registration certificate for EU citizens, so it is not the Ukrainian route, and this guide promises nothing about it. Ukrainian nationals use the permission routes that apply to third-country nationals, and we bring in immigration specialists where a file needs them. The tax residency and non-dom side is what we deliver as a fixed-price service, and the day counting is set out in the Cyprus 60-day rule.

Why do people choose Cyprus over other tax havens?

Because it is somewhere you can live a normal life, which most of the alternatives on the list are not. Tax is what puts Cyprus on the shortlist; something else entirely is what keeps people here five years later.

Cyprus works in English — business, banking, professional services and most of daily life — so the second language problem that comes with moving anywhere else in the European Union does not arise. It has among the lowest violent crime rates in the EU. There are people from everywhere here already, so no one is the only foreigner in the room. Business and real estate are booming, and the state is broadly open to people doing business without wrapping the activity in regulation. Groceries — meat, fruit, vegetables — are cheap by European standards. And the beaches are not a brochure line: in a Cyprus winter you can still swim, and the summers are what people cross the world for.

The push side, kept to the facts, is not about rates at all. It is that the Ukrainian regime is expressly temporary in its own drafting. The military levy lives in the transitional provisions and runs to the third calendar year after martial law ends. The sole-trader social contribution waiver has been suspended one year at a time. Resolution 18 has been amended repeatedly since February 2022, and the limits quoted earlier in this guide are simply the version in force on 11 August 2026. Diia City itself has been amended several times since it was enacted. None of that is a criticism of the policy; it is a description of planning horizon, which is the thing a founder is actually buying when they incorporate somewhere. Alongside it sits the cost of capital: the National Bank's key policy rate has stood at 15.5% since 30 July 2026, so hryvnia debt is expensive. We do not publish Ukrainian growth or inflation figures here, because we could not verify them from an official source in the research behind this page, and a number we cannot source is a number we leave out.

Can a Ukrainian e-commerce brand sell into Europe through Cyprus?

Yes, and for a Ukrainian seller the market-access question usually outweighs the tax one. Selling into the European Union from outside it means import formalities, import VAT and a separate registration for distance sales and digital services — friction applied per order, and paid for in conversion rate as much as in cash.

A Cyprus company changes the position by being inside the union rather than adjacent to it. It carries an EU VAT number your business customers can check in VIES, it zero-rates intra-EU business supplies, and it accounts for consumer sales across the bloc through the one-stop shop instead of registering country by country. It also solves the mundane problems that decide whether a store scales: euro settlement, EU merchant acquiring, and payouts that do not run through a monthly transfer ceiling.

Where this normally falls apart is the bookkeeping. A store produces thousands of small transactions in several currencies with a VAT treatment that changes by customer type and destination, and a quarterly export into a spreadsheet is not a reconciliation. Sumly's Shopify and WooCommerce plugins pull orders, refunds, fees and payouts into the ledgers with the right VAT codes as they happen, so the return is assembled from the sales themselves rather than reconstructed at the deadline.

Part 3: How the move runs

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

What does the move look like, month by month?

Timelines depend on your own file, so read this as sequence rather than schedule.

• Before anything else — and this is where we start. We establish with you how the Cyprus company will be funded, given the currency position in the first section. We put a Ukrainian adviser from our network on the departure sequence, and we flag the 60-days-before rule in article 179.3 if you are leaving for permanent residence abroad.
• Month 1. We register the Cyprus company, with the books opened the day you order, and we diarise the 60-day CFC notification from the incorporation date — it is the deadline founders miss, and it is ours to remember, not yours.
• Months 1–3. We register for VAT and, where relevant, social insurance, employees and UBO, and get banking and EU payments working. We move the bank mandates, the bookkeeping and the staff management to the Cyprus side, because article 133.1.5 measures exactly those three things.
• Months 3–6. You take up the directorship that anchors the 60-day rule and take the permanent home it requires; we tell you what qualifies. Your Ukrainian adviser closes the ФОП. Together we settle what happens to the ТОВ and plan any distribution against the monthly currency ceiling.
• Month 12 onward. Your adviser files the CFC report with your annual return by 1 May, claiming the exemption rather than assuming it. We apply for the Cyprus tax residency certificate and the non-dom registration, and we keep the substance record current — board minutes, contracts, staff and premises.

What mistakes do Ukrainian founders actually make?

The costly ones are procedural, not exotic.

Assuming the share capital can simply be wired from a Ukrainian bank. Inserting a Cyprus holding company in order to release an old dividend, and meeting the six-month holding rule instead. Budgeting for dividends out of pre-2023 retained earnings. Believing the widely repeated claim that CFC penalties are frozen until the war ends. Missing the 60-day notification because the annual report was the only deadline anyone mentioned. Assuming the de minimis or the treaty exemption removes the filing obligation as well as the tax. Running an IP Box company and never checking it against the 13% effective-rate floor. Keeping the bookkeeper, the payroll and the online banking in Ukraine while calling the company Cypriot. Leaving the ФОП registered. Reading treaty rates off the Convention page without the Protocol. And modelling the military levy at 1.5%, or as something that ends with martial law.

Two worked examples

A services ТОВ on the general system, €200,000 of profit. In Ukraine the company pays 18%, leaving €164,000, and the founder taking it as a dividend from a corporate income tax payer pays 5% personal income tax plus the 5% military levy — about €16,400 — to keep roughly €147,600. Through Cyprus the company pays 15%, and a non-dom shareholder distributing the remainder meets only the health contribution, capped at €4,770, keeping about €165,500. The gap in year one is real; the calculator at the top of this page compounds it, because the saved amount is also invested and Cyprus does not tax the return.

A single-tax group 3 consultancy at €150,000 of revenue. Here the honest answer runs the other way. Five percent single tax plus the 1% levy is about €9,000 on turnover, plus the flat social contribution — a burden a 15% profit tax does not beat at that margin. What Cyprus offers this founder is not a lower rate. It is the absence of a turnover ceiling that stops the regime working at roughly UAH 10.1 million, an EU banking relationship, invoicing to European clients with a VIES-checkable number, and no monthly limit on moving their own money. If those are not constraints you feel, stay where you are and keep the 6%. We would rather say that than sell a move that does not pay.

Both examples assume full distribution and headline rates, and neither is a substitute for running your own numbers with the Diia City alternative on the table.

Part 4: Who does the work

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

Do it yourself — or have Sumly do it

Both are real choices, and the deciding factor is usually how much unfamiliar administration you want to carry while also managing a departure file at home. Doing it yourself means the Registrar's forms and fees, a registered office you arrange, VAT and VIES registration, provisional tax twice a year, annual statements and books an auditor will accept. Our side of it comes down to three numbers and no hidden fourth: €950 one-time to form the company, €39 a month for the bookkeeping software, €390 a month if you want your own Sumly certified bookkeeper — books opened on day zero, every return prepared box by box.

The software by itself runs the whole company, whether you are operating it from Cyprus or still partly from Ukraine: invoicing, AI double-entry bookkeeping that books your documents for you, 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.

Sumly offers all of it to everyone who asks: a virtual address with PO box, including digital scanning of your post into the dashboard wherever you are; nominee director and secretary where a structure genuinely needs them; the Yellow Slip, which is an EU-citizens-only route and therefore not the Ukrainian one; every registration handled — VAT, social insurance, employees and UBO; and audit through Partner Auditors.

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, because that is complex expert work and precisely the kind of thing that should be examined with you before anyone puts a number on it.

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 Ukrainian founder that split is the whole point. The Ukrainian side of this move needs a Ukrainian adviser, and we will say so every time it comes up. The Cyprus side — the company, the books, the filings, the residency, and the substance record that article 133.1.5 will be measured against — is one provider, one dashboard and four published prices. That is what makes Sumly the best choice for Ukrainian founders creating a company and relocating to Cyprus.

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

Sumly is the best accounting software for a Cyprus limited company — because it is built for exactly one thing, Cyprus tax law: all 16 Cyprus VAT codes mapped to the official VAT return boxes, VIES and provisional tax native, not a localization. That is the claim, and every line under it can be checked.

The two Cyprus-built alternatives a Ukrainian founder is likely to 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.

Put without decoration, that is five claims: the best support, the best bookkeeping software, the best AI for bookkeeping, the best bookkeeper, the best prices — and everything done easily. The detail is published — Sumly vs Cybooks and Sumly vs Balabook — and against the international tools you may already be running, Xero, QuickBooks and Sage.

On the IP Box, one line is worth repeating: the IP Box is the largest single line in a Cyprus product company's tax position — and the easiest one to forfeit through bookkeeping that was never set up for it. The application starts as a conversation, which for a Ukrainian founder has a second reason behind it — the interaction with the CFC effective-rate test needs designing at the same time.

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 Ukrainian founders actually ask

Frequently asked

Can a Ukrainian resident legally wire the share capital for a Cyprus company?

Under the current regime, generally not through a Ukrainian bank. NBU Resolution 18 prohibits cross-border transfers of currency values from Ukraine except in an enumerated list of cases, and that list contains no exception for a resident subscribing for shares in, or capitalising, a foreign company. The routes that do exist are funds already held outside Ukraine, the small personal monthly limits, or a specific NBU permission. Anyone telling you the wire is routine has not read paragraph 14.

How much can a Ukrainian company repatriate as dividends each month?

No more than EUR 1,000,000 in a calendar month, and only on four conditions: the dividends must be accrued on results for a period starting on or after 1 January 2023, the transfer must be made by the issuer itself, the issuer must have existed for at least twelve months, and the non-resident must have held the shares for at least six months. Pre-2023 retained earnings and reserve capital cannot be paid out through this channel at all.

Are Ukrainian CFC penalties suspended until martial law ends?

No, and this is the most widely repeated error in Ukrainian-language content on the subject. The penalty holiday in the transitional provisions covered the 2022 and 2023 reporting years only. The separate wartime suspension of statutory time limits ran until 1 August 2023 and expressly excluded reporting under article 39-2. Reports are due and penalties apply now, priced off the subsistence minimum for the reporting year.

Does Ukraine charge an exit tax when a founder leaves for Cyprus?

No. The Tax Code sets a closed list of national and local taxes and forbids the introduction of national taxes it does not provide for, and nothing in that list deems a disposal on ceasing residence. What exists instead is a compliance step: a person leaving for permanent residence abroad files a declaration no later than 60 calendar days before departure and receives a clearance certificate for the customs authorities. It is a filing, not a charge.

Is a Cyprus company at 15% actually cheaper than Diia City or single tax group 3?

On the corporate line, usually not, and you should hear that before you pay anyone. A Diia City resident pays 9% only when it distributes and nothing while it reinvests, with 5% personal income tax for specialists. Single tax group 3 is 3% or 5% of turnover plus a 1% military levy. Cyprus wins on currency freedom, EU banking and VAT, permanence and the non-dom position for someone who actually relocates — not on the headline rate.

Can Ukraine treat my Cyprus company as a Ukrainian taxpayer?

Yes, and article 133.1.5 is wider than the usual place-of-effective-management test. Where the company could also be managed from another foreign state, Ukraine is designated the place of management if any one of three things happens in Ukraine: its bank accounts are operated, its accounting or management accounts are kept, or its staff are managed. Any one alone is enough. Keeping the bookkeeper and the online banking in Kyiv is the fastest way to lose the structure.

What are the real Ukraine–Cyprus treaty rates in 2026?

Dividends at 5% or 10%, and interest at 5%. The catch is where you read them: the legislature publishes the 2012 Convention and the 2015 Protocol as two separate documents and does not consolidate the second into the first, so the Convention page still shows the original pre-2020 rates. Most published content copies them. The 5% dividend rate now needs both a 20% direct holding and at least EUR 100,000 invested — an and, not an or.

Should I close my ФОП when I move to Cyprus?

Treat it as load-bearing rather than housekeeping. The residency test in article 14.1.213 says that registration as a business entity is by itself a sufficient ground for locating your centre of vital interests in Ukraine, alongside the permanent residence of your family. Leaving an active ФОП registration open hands the tax authority a statutory reason to treat you as still Ukrainian-resident, whatever your day count says.

Does Sumly advise on Ukrainian tax?

No. Sumly builds and runs the Cyprus side: forming the company, opening the books from day zero, preparing Cyprus VAT, VIES, provisional and corporate returns, and handling tax residency and the non-dom application. This guide quotes Ukrainian primary legislation so you can see the shape of the decision, but how it applies to your facts is a question for a Ukrainian adviser. Where a case needs one, we connect you with expert lawyers from our network.

Keep reading

• Every country's route to Cyprus — the departure guide for wherever you are now
• Cyprus non-dom status — the 17-year exemption in detail
• The Cyprus 60-day rule — day counting and the residency certificate
• What changed in the 2026 Cyprus tax reform
• How to register a company in Cyprus and what it costs
• Cyprus tax benefits for foreigners and the IP Box service

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 outcome. Ukrainian figures are stated for 2026 from the Tax Code, the 2026 Budget Law, the unified social contribution law, the Diia City law and National Bank Resolution No. 18 in the version of 11 August 2026, with the Ukraine–Cyprus Convention read together with its 2015 Protocol; hryvnia amounts expressed as multiples of the minimum wage or the subsistence minimum are converted arithmetically from those statutory bases. 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.