Management & permanent establishment
Actual central management and fixed business facilities can create German tax exposure; a foreign registered address is not sufficient.
Sections 10 / 12 AO ↗
Residence & Relocation
Cyprus · Non-Dom
A real new home in the Mediterranean, with residence, personal income and company structures assessed separately.
Where it fits
The location must fit the plan.
For people genuinely relocating to Cyprus who meet the domicile and residence-history conditions.
Scope
From context to execution.
- Review of ownership, activity, residence and countries involved.
- Agreed responsibilities, document checklist and open specialist questions.
- Coordination of company or residence documents, banking preparation and local professionals within the agreed scope.
- Document handover and a schedule of ongoing obligations.
Non-dom treatment may exclude specified dividends and passive interest from SDC. Deemed domicile generally refers to residence in 17 of the preceding 20 years. As of 09/2026.
Eligible individuals may extend treatment for up to two additional 5-year periods, at EUR 250,000 per period, subject to application and conditions. As of 09/2026.
GESY can still apply; 2.65% is relevant to specified passive income, subject to the applicable base and cap. As of 09/2026.
The 60-day residence route requires every statutory condition to be met. As of 09/2026.
Requirements & Substance
What needs to be clear first.
Document the home, actual days, family circumstances, business roles and domicile history. A residence certificate alone does not settle competing residence claims.
Timing
A sequence with clear dependencies.
Document review, specialist clearance, filing and account or status decisions follow separate processes. Once the documentation and scope are clear, we agree a schedule. Authority and bank decisions cannot be guaranteed.
Ongoing Duties & Cost Drivers
The structure must work day to day.
Housing, insurance, filings and residence evidence require ongoing attention. A separate company has its own obligations.
German connections
From a German perspective.
Preferential taxation may be relevant under section 2 AStG for German nationals when the other conditions are met. Review German homes, interests, ownership and treaty position before moving.
Controlled foreign companies
Control, income type and actual taxation matter. The low-tax threshold is below 15% (as of 09/2026); EU/EEA substance rules require evidence.
Sections 7–13 AStG ↗Foreign-interest reporting
Foreign businesses and shareholdings may trigger notification duties. Conditions, thresholds and deadlines need review.
Section 138(2) AO ↗Exit taxation
Departure or restrictions on German taxing rights can trigger taxation of unrealised gains on covered interests, subject to personal conditions.
Section 6 AStG ↗Remaining German interests
German nationals meeting all relevant conditions may face extended limited taxation for up to 10 years after the departure year (as of 09/2026). Preferential taxation alone is insufficient.
Section 2 AStG ↗Tax treaties
Residence, income, entitlement and the current treaty text determine relief. The existence of a treaty is not a blanket exemption.
Treaty status ↗This overview does not replace case-specific review by directly appointed, qualified legal and tax professionals.
Read on
Guides and terms for this country.
Formation21 September 202617 min
Which company suits whom: the US LLC, Cyprus, Bulgaria, Estonia, Poland and the residence question
The right country is not the cheapest one but the one that fits your business, customers and residence. For location-independent entrepreneurs that is usually the US LLC: affordable, online, and without US income tax where there is no US business activity. The article shows who it suits permanently, and when Cyprus, Bulgaria, Estonia or Poland are the better choice.
Read the articleResidence21 September 202616 min
Exit tax: how to plan your move with a GmbH shareholding
Exit tax slows down entrepreneurs who want to move, but it can be planned well and in many cases avoided altogether. This article explains who it concerns, how the value is determined, how to pay in seven interest-free instalments or be released entirely under the return rule, works through a move to Cyprus and sets out the sequence in six steps.
Read the articleResidence21 September 202616 min
Moving your residence properly: how to end your tax liability in Germany
Deregistration is just a form; the clean tax break comes from facts you create yourself. This article shows how to move your home and your presence, how visits to Germany remain possible, why life as a perpetual traveller is a recognised model too, and how Cyprus’s 60-day rule helps frequent travellers.
Read the article
Questions & Answers
Worth knowing.
Is non-dom an immigration permit?
No. Immigration, residence and domicile are distinct.
Does it cover all income?
No. It concerns specified income and taxes.
Is a brief stay sufficient?
No. All conditions of the residence route must be met.
Do I need a company?
Not automatically. This is a separate decision.
Do German obligations end immediately?
No. Homes, income, ownership and exit provisions need review.