Elite Noir Consulting & Concierge
International Tax
Strategy Blueprint
The advanced guide to structuring your wealth across multiple jurisdictions, legally.
Confidential by default
This Blueprint is in preparation. Join the waitlist and we will let you know as soon as it is available.


For many entrepreneurs and investors, Cyprus can be an efficient EU tax residence, depending on their facts. You can qualify with as little as 60 days of physical presence a year, alongside a few other conditions explained below. Under the Non-Domiciled regime dividends are generally exempt from SDC and income tax, and most capital gains outside Cyprus real estate are not subject to Cyprus capital gains tax (a 2.65% GESY health contribution still applies, capped). Full EU member benefits. Non-Dom status lasts up to seventeen years from when you establish Cyprus tax residency. This guide explains exactly how it works, who qualifies, what it costs, and how to execute the move without mistakes.
What this guide is not. It is not theory. It is not motivational content. It is not a Twitter thread expanded to 34 pages. It is the operational reference we give our clients before their consultation, so they walk in already understanding the structure and can spend their time on their specific case rather than the basics. Every chapter is built from the primary law and current practice, with real numbers, real timelines, and the mistakes that most often derail a move.
After reading this guide, you will know whether Cyprus Non-Dom is the right move for your situation. You will know the difference between the 60-day rule and the 183-day rule, and which one applies to you. You will know what your effective tax rate will be, what your relocation will cost, and what the timeline looks like from first decision to fully operational status. You will know what to do, what to avoid, and what questions to ask your advisers.
Who this is for
- Entrepreneurs preparing to relocate internationally and wanting the full picture before deciding
- Founders building or restructuring a multi-country setup with Cyprus, US LLC, holdings, and offshore elements
- HNWIs who want a complete reference library on their side instead of paying advisers for every basic question
- Anyone who has read one ENCC guide and knows the quality is worth paying for at scale
Who this is not for
- Anyone who only needs one specific answer (buy that single guide instead, €39 to €99)
- People expecting a course, a coaching programme, or one-on-one advice (this is reference material)
- Anyone unwilling to invest 10+ hours of focused reading to extract the full value
What's Inside
The Cyprus Non-Dom Guide (46 pages)
The definitive guide to establishing tax residency in Cyprus under the Non-Domiciled regime.
1
Chapter 1: The Four Pillars Framework
2
Chapter 2: Tax Residency in Practice
3
Chapter 3: The Holding Company Decision
4
Chapter 4: Double Tax Treaties Explained
5
Chapter 5: CFC Rules and How to Survive Them
6
Chapter 6: Economic Substance Requirements
7
Chapter 7: Transfer Pricing for Entrepreneurs
8
Chapter 8: The Cyprus + US LLC Structure
9
Chapter 9: The Cyprus Holding + EU Operating Company
Chapter 10: IP Box Regimes Worked Example
Chapter 11: Crypto and Digital Asset Structuring
Chapter 12: Real Estate Across Jurisdictions
Chapter 13: Exit Planning
Chapter 14: Inheritance and Generational Wealth
Chapter 15: Jurisdiction Comparison Matrix

Sample Preview
From Chapter 8, the Cyprus + US LLC Structure

The structure is legal, disclosed, and widely used by non-US founders serving global clients. The US LLC is disregarded for US tax purposes (no US employees, no US office, no effectively connected income). Form 5472 is filed annually as an information return. Failure to file is a $25,000 penalty per form. The Cyprus side handles the actual taxation: 15% corporate tax on the
LLC’s profits, which flow up to the Cyprus company. Dividends to you under Non-Dom then carry 0% Special Defence Contribution and 0% income tax (a 2.65% GESY contribution still applies, capped). The US LLC gives you a US bank account, Stripe Atlas eligibility, and credibility with US-based clients. The Cyprus LTD gives you the tax home and the EU access. For some European entrepreneurs with global customers, the combination can work well in 2026, if substance and reporting are in order.
Written by practitioners.
Elite Noir Consulting & Concierge is a premium structuring firm based in Larnaca, Cyprus. We coordinate legal, fiscal, and operational execution for entrepreneurs, freelancers, and investors relocating internationally or building cross-border structures. Every guide we publish is written by the ENCC team from the primary law and current practice. No theory, no copied content, no recycled blog posts.



