Click here to view the July newsletter
Why Businesses Are Looking Beyond Cyprus in 2026
The announcement of Cyprus’s tax reform – slated for implementation on January 1, 2026 – has stirred strategic recalculations among international entrepreneurs and holding companies based on the island.
Here’s what’s prompting the reconsideration:
- Corporate tax hike from 12.5% to 15%
- Abolition of deemed dividend distribution
- New withholding tax on actual dividend payments – even if reduced to 5%
- Increasing scrutiny from EU tax bodies
- Uncertainty tied to Cyprus’s election cycle, potentially delaying or altering parts of the reform
While the reform is framed as a modernization effort, it directly impacts how companies manage profits – especially for those using Cyprus as a base for holding structures or dividend distribution.
This has led many to ask:
Where should I relocate my business to keep control over dividends, taxation, and compliance?
The answer depends on your strategy:
- Do you want to distribute dividends flexibly with a transparent EU structure
- Or do you prefer to reinvest profits and grow your company tax-free until you’re ready to distribute?
Let’s explore your two smartest options: Malta and Estonia.
If You Want to Distribute Dividends: Why Malta Makes Sense
Malta is quickly gaining popularity among companies seeking favorable dividend treatment within the EU. Unlike Cyprus, Malta operates a full imputation system for dividends – a unique setup that can significantly lower effective tax burdens for shareholders.
Malta’s Corporate Tax Advantage Explained
- Headline Corporate Tax Rate: 35%
- But Here’s the Catch: Up to 6/7th of that tax can be refunded to shareholders, bringing effective tax rate down to 5%.
- No withholding tax on outbound dividends to non-resident shareholders.
- EU Member State status ensures passporting rights and regulatory alignment.
This makes Malta particularly attractive for holding companies, financial services entities, and entrepreneurs who rely on cash extraction rather than reinvestment.
Ideal For:
- International investors seeking regular dividend payments
- Entrepreneurs running remote operations from within the EU
- Digital businesses, IP holding companies, or international consultancies
“Malta allows for tax-efficient dividend extraction without reputational or regulatory risks. It’s an EU-compatible version of what Cyprus used to be,” notes a financial advisor from the European Tax Institute.
If You Want to Reinvest Profits: Choose Estonia for Simplicity and Growth
If you’re less focused on immediate cash withdrawals and more on scaling your business, Estonia is a top-tier choice. The Estonian tax system is admired globally for its simplicity and innovation.
Estonia’s Tax Model: Only Pay When You Payout
- Corporate Tax Rate: 0% on retained profits
- 22% corporate tax only applies on distributed profits (dividends)
- No withholding tax on outbound dividends and interests
- No annual corporate income tax declaration needed unless profits are paid out
This encourages businesses to keep profits in the company, reinvest them, and grow sustainably without the friction of annual tax deductions.
Digital-First Nation
- Fully digital business registration and management via Estonian e-Residency
- Access to the EU single market and a forward-thinking startup ecosystem
- Easy-to-use online tools for tax filings and legal compliance
Ideal For:
- Startups and scaleups focused on long-term growth
- SaaS companies, tech ventures, or digital service providers
- Founders who want clean, low-friction operations without bureaucracy
“Estonia’s model is entrepreneur-friendly. You’re not penalized for growing your company, only for taking money out,” says a founder who moved his digital agency from Cyprus to Tallinn in 2022.
Key Comparison: Malta vs. Estonia
Feature | Malta | Estonia |
---|---|---|
Best for | Dividend distribution | Reinvesting profits |
Effective tax rate on profits | ~5% (with refund) | 0% (until distributed) |
Dividend withholding tax | None (non-residents) | 22% (only when paid) |
EU member | ✅ Yes | ✅ Yes |
Compliance system | Refund-based | Distribution-based |
Setup support | Strong accounting & legal firms | e-Residency program simplifies everything |
Public perception | Stable, compliant | Transparent, digital-first |
Why Estonia’s Corporate Tax System Is Perfect for Growth Companies
Let’s say you’re running a fast-scaling data-centers business, like a server housing company that invested €10 million in 2024 and is growing rapidly.
The plan is to reinvest every euro of profit in the coming years, attract new investors, and aim for a strong shareholder exit in about seven years.
This is exactly the kind of business Estonia’s corporate tax system was built for.
Here’s why: In Estonia, retained and reinvested profits are not taxed at all.
That means as long as the company keeps profits in the business – buying servers, expanding infrastructure, hiring top talent – there is zero corporate income tax. You pay tax only when profits are distributed (e.g. as dividends).
This is a game-changer for growth companies that:
- Reinvest all earnings to accelerate expansion,
- Delay profit distribution until a planned exit,
- Want to maximize cash flow during the high-growth phase.
Estonia = 0% tax on reinvested profits
Unlike traditional tax systems that tax annual profits regardless of how they’re used, Estonia rewards long-term growth. The tax bill only arrives when the company pays dividends – typically at the exit stage. Until then, capital stays inside the company, fueling scale.
For our server housing example:
If the business earns €2 million profit per year and reinvests all of it for seven years – that’s €14 million of untaxed reinvestment power before any tax is due. In most other countries, you’d lose 20–30% of that to corporate tax every year.
Investor-friendly structure
Estonia is in the EU, uses the euro, offers fast digital administration (e-Residency, online company management), and has a solid reputation for legal clarity, compliance and transparent tax rules – all important for attracting international investors.
In short:
For high-growth, capital-intensive businesses planning for a future exit, Estonia offers one of the most entrepreneur-friendly tax systems in the world.
Zero tax on reinvested profits = more fuel for growth.
That’s why forward-looking founders are choosing Estonia as the home for their corporate structure.
Estonia vs Malta: Where Should You Build Your EU Data Center?
Thinking of launching a data center or AI server farm in Europe?
While Malta offers tax perks and CSP – backed holding structures, it lacks land, cooling climate, and energy scalability.
Meanwhile, Estonia is quietly becoming Europe’s most agile base for data-heavy infrastructure – offering zero tax on reinvested profits, fast permits, cold weather, and cheap grid access.
We’ll unpack this fully in our next article. Stay tuned – it’s not just tax planning, it’s future-proofing.
FAQ: Navigating Business Relocation from Cyprus
Is it difficult to move a business from Cyprus to another EU country?
It’s manageable with the right legal and accounting guidance. Both Malta and Estonia have systems in place to assist foreign entrepreneurs with redomiciliation or setting up new entities.
What if I want to keep my IP in Cyprus but move profits?
You can explore hybrid structures or set up a holding company in Malta or Estonia while keeping operational functions in Cyprus.
Should I wait until 2026?
It’s smart to start the process now, especially since tax and company relocation planning can take 6 – 12 months for smooth transitions.
Can I still use Cyprus for other benefits?
Yes, Cyprus remains attractive in other areas (e.g., shipping, residency programs), but tax optimization may require a new strategy post-reform.
Conclusion: Strategic Relocation Is About Fit, Not Just Rates
As Cyprus evolves its tax landscape, businesses should be proactive, not reactive.
If your priority is to maximize dividend payouts, Malta offers a clean and legally secure route through its tax refund mechanism.
If your focus is on reinvesting, scaling, and minimizing tax until you exit, Estonia’s reinvestment-friendly system gives you full control.
In either case, planning early ensures compliance, continuity, and peace of mind.
Click here to view the July newsletter