Holding · Cyprus
Optimized setup
A share-for-share exchange: the existing company moves under a Cyprus holding. Nobody sells for cash.
The diagram, the amounts, and the statutes below come from Ricardo Gorski’s post (Tax.One), 15 October 2026. Liberty Stack is reproducing them. This is not tax advice, and it is not a check of the rates.
The three moves
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Share swap — €0
You own your company. The holding issues its own shares in exchange for yours. Same owners, same value, one company added on top: the post says there is nothing to tax, because nobody is paid in cash.
The example uses a UK company worth about €3,500,000. Before the swap, the post describes a written request to HMRC (advance clearance): a file on the new structure and the business reasons.
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Reinvest — 0% inside the holding
Dividends go up to the holding. From there they can go into real estate, other companies, or stocks. While you remain tax resident where you are, a distribution to yourself is still taxed there. Money that stays in the holding is not that distribution.
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Later, as a Cyprus non-dom
The post leaves open a move to Cyprus under non-dom status. A distribution to you as an individual is described at 0% dividend tax. The health contribution remains: GESY at 2.65%, capped at €4,770 a year, on the post’s figures.
The worked example
UK company, amounts as published.
| Item | Cited amount |
|---|---|
| Value of the UK company | about €3,500,000 |
| Shares issued by the holding | €1,000 |
| Share premium | about €3,499,000 |
| Tax on the exchange | €0 |
| Flow | Cited rate |
|---|---|
| UK withholding tax on dividends paid to the holding | 0% |
| Most EU countries (Parent-Subsidiary Directive) | 0% |
| Cyprus tax on dividends received by the holding | 0% |
| Cyprus tax on a later sale of the shares | 0% |
| Personal UK dividend, in the example | 39.35% |
| Personal distribution as a Cyprus non-dom | 0% + GESY 2.65% (cap €4,770/year) |
Statutes cited in the post
- United Kingdom: section 135 TCGA, with prior HMRC clearance
- Ireland: section 586 TCA
- Germany: §21 UmwStG
- Netherlands: aandelenfusie
- Rest of the EU: Merger Directive
What the post does not settle
Incorporation, business plan, bank accounts, valuation, clearance, share-exchange agreements, board resolutions: the post says the file takes months. Big 4 firms often quote more than €100,000, sometimes a percentage of the company’s value.
The 0% depends on the business purpose, the clearance, the substance, and the CFC rules of the country where you live. These rates are the ones in the 15 October 2026 post. Local law may have moved.
Cyprus business page Ranking, Holding profile
Source of the graphic and the figures: Ricardo Gorski, @ricardogorski, 15 October 2026. The original image carries the Tax.One mark.
Company in Singapore, life in Cyprus
On 24 July 2026, Marc Lou (@marclou) answers a French tax calculation. He publishes no diagram. He states three rates, then a take-home figure.
- Singapore corporate tax: 17%
- Cyprus dividend tax: 0%
- Cyprus healthcare contribution: 2.65%
He gets to $21,200 kept per month, against $13,700 in the French story he is answering. Invested in the S&P 500, he puts the gap at $1.58M after ten years, and more by age 60. He writes that Cyprus tax on that gain is 0%.
On 14 August 2026 the same account sums it up in one line: French, living in Cyprus, company in Singapore. Post.
The 24 July post does not say where the company’s decisions are made, and it does not name non-dom status. A Singapore company run from Cyprus can be treated as resident where control is exercised. He cites no statute.
Source of the rates: Marc Lou, @marclou, 24 July 2026. Sheets: Singapore, Cyprus.
IP Box: company and residence in Cyprus
On 20 September 2026, Ricardo Gorski describes another setup, both layers in the same place. The photo on the post is a sea view, not a diagram.
Published example, €1,000,000 of qualifying software profit:
- 80% IP Box deduction: €800,000
- Taxable base: €200,000
- Corporate tax at 15%: €30,000
- Non-dom dividend: 0%, plus GESY at 2.65%. He writes a cap of €180,000, which is €4,770
He presents the IP Box as an EU regime. He does not spell out which works qualify, or the R&D spend ratio that limits the deduction.
Source: Ricardo Gorski, @ricardogorski, 20 September 2026.
What the search did not turn up
No numbered post turned up for a company in Estonia, Wyoming, Hong Kong, or Dubai, with life in Cyprus. On 26 August 2026, Gorski compares living in Cyprus or Dubai: both are residences, not a company on one side and life on the other.
A different case, from a different source: living in Poland with a US LLC. Those are Polish tax rulings, not a post.
To choose the holding’s country: Latvia, Cyprus, Bulgaria. The rates are those of October 2026.