The Cyprus Government in an effort to boost the competitiveness of the newly launched Cyprus Non-Domicile Scheme has recently proceeded to also amend the criteria that need to be satisfied by any individual who wishes to become a Cyprus tax resident.
These significant amendments to the Cyprus tax environment have now let to new advantageous co-ordinates for all persons interested in obtaining the Cyprus Tax-Residency and thus enjoy the country’s beneficial tax regime.
More specifically, as per unanimous approval by the Cyprus Parliament of a recent bill of date 14 July 2017, the classification of ‘Cyprus Tax Resident Individual’ can now be duly granted to any person who do not spend more than 183 days within a tax year at any other State, and is not a tax resident at any other country within that same tax year.
From thereon, the voted amendment to Article 2 of the Income Tax Law N118 (I)/02 in reference to the criteria for determining the rights of an individual to be considered a Cyprus tax resident requires a triple criterion to be satisfied which is comprised of the following:
- The individual is expected to spend a minimum of 60 days within the year under assessment in the Republic of Cyprus
- The individual maintains a permanent housing residence in Cyprus which can be either owned or rented
- The individual carries out any kind of business within Cyprus or is employed in Cyprus, or holds an office as a Director of a Company which is tax resident in the Cyprus jurisdiction, starting at any time during the tax year under consideration and throughout to the completion of that year.
Additionally, the very advantageous applicable tax rate bands for Cyprus tax residents are currently the following, and these rates are applicable to the entirety of their income earned worldwide.
Income bands of net chargeable income with net chargeable income being the resulting net Income following all allowable deductions as per the Cyprus Income Tax Regime:
- For up to € 19.500: Tax rate is Nil on the first €19.500
- For the €19.501 to € 28.000: Tax rate is 20%
- For the next € 28.001 to € 36.300: Tax rate is 25%
- For the next € 36.301 to €60.000: Tax rate is €30%
- For over €60.000: Tax rate is 35%
Thus, if you are interested in this Scheme, here at White November Corporate Services, our highly experienced teams can readily offer you the necessary detailed and specific guidance tailored to your requirements towards obtaining the advantageous Cyprus tax residency as well as the non-domicile individual status, and we look forward to attending your tax residency plans and enquiries.
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There were changes to the Malta Residence and Visa Programme as per Legal Notice 189 of 2017 as below:
- Additional EUR5000 non-refundable contribution per parent or grandparent of the main applicant or of the spouse at application stage
- EUR30,000 contribution fee now covers main applicant, spouse and the children of the main applicant and/or the spouse
- Age limit (27) for unmarried, economically dependent children was waived off. Moreover, children of the main applicant and/or spouse, will not lose the residency rights on their 27th birthday, or if they become economically active or get married. Option to obtain residency for their suppose and direct dependants is also available (subject to EUR5000 non-refundable administration fee per person and successful due diligence check)
- The requirement for the main applicant and his/her dependants to spend outside of Malta a period that exceeds either six consecutive months or an aggregate period of ten months in any four-year period from the appointed day was removed. The main applicant and dependants will be eligible to apply for long term residence
- The main applicant may include children born or adopted after the approval date (subject to EUR5000 non-refundable administration fee per person and successful due diligence check)
Towards the end of the sixties one very famous Italian performer, Domenico Modugno, was singing ‘Meraviglioso’, which was saying “[…] but look around you/ gifts that have made you / They have invented the sea / You say ‘I have nothing’/ It seems nothing the sun? […]” and this song seems to be deeply related to the beauty of living in the so called “Bel Paese”, that is to say, Italy.
How beautiful, how wonderful indeed, would be to live in such a beautiful Country, surrounded by art, friendly people and lovely villages, without forgetting the bonus of staying in the homeland of the best food in the world and completed – like a cherry on a cake – by a temperate weather?
New guidelines on setting a residency in Italy
It is a very recent news, that one that was published in the “Gazzetta Ufficiale Italiana” during January 2017, and clarified with the document about ‘Revenue Measures’ of the 8th of March, that establishes, the requirements and the guidelines in order to set the residency in Italy.
This new measure outline the possibility to move the tax residency in Italy, upon the payment of a flat rate of 100,000 Euro on incomes produced abroad (those produced in Italy would be taxed at normal rates). The application of this new regime is not only optional, but there is no need, for the applicant, to declare the amount of the foreign income or capital.
The new resident would be fully equated to other taxpayers in Italy, thus subject to the fact that – to be considered resident in Italy – the individual shall linger in the Country more than the half of the tax year.
Furthermore, in the case in which the individual would like to move with its family, there would be the possibility of benefitting of another additional flat rate of EUR 25,000 to compute with the principal tax, in order to register any relative of the main taxpayer.
Main requirements
As main requirements, we can definitely mention:
- the applicant should not have been resident in Italy for the past 9 years
- the supply of personal and identity-related records
- the indication of the previous jurisdiction/s in which the individual had the last tax-residence
Once the application would be approved (even with silent consent), the individual can benefit of this flat rate for the next 15 years.
As conclusion, even if it is always important to underline that every individual situation should be carefully analysed, we can say – with no doubt – that finally Italy took the field with other tax-friendly countries for high wealth individuals, such as Portugal or Malta.
Contact
Simona Angotzi
Corporate Administrator
simona.angotzi@whitenovember.com
Simona Angotzi is a Corporate Officer in White November Group Corporate Department.
