BLK Advisory Services · The 3% Advantage
97%
Keep what your technology earns.
Profit from qualifying software or IP can be taxed in Cyprus at approximately 3%. The remaining 97% stays in the business. We set it up, staff it, book it, bank it and run it. Regulated Cyprus advisors issue the tax opinion.
Your platform earned it. Now structure it.
- 100%
- documented source of funds
- 8–12 weeks
- from first call to a running structure
- ≈3%
- effective tax on qualifying IP profit
- 0%
- Cyprus withholding on dividends to non-resident shareholders
- compliant regime, built on the nexus rule
The important number is not 3%. It is the 97% that stays in your business.
Cyprus deducts 80% of qualifying IP profit. The remaining 20% is taxed at the 15% corporate rate. That is an effective rate of approximately 3% on the qualifying share.
- 80%
- deducted from qualifying IP profit
- 20%
- remaining taxable amount
- 15%
- Cyprus corporate rate
- ≈3%
- effective on qualifying IP profit
The regime is OECD-compliant and built on the nexus rule: the share of profit that qualifies depends on the R&D expenditure behind the IP and who incurred it. It is not automatic.
This is not for everyone.
The regime rewards genuine builders. Brands and trademarks don’t qualify; your code does.
Copyrighted software can qualify.
Platform code, engines, trading bridges, algorithms, models and proprietary tooling. Brands, trademarks and other marketing IP are excluded.
It earns qualifying income.
The IP has to contribute to profit. That includes licence and royalty income, and qualifying income embedded in the products and services you sell.
Who built it matters.
The benefit depends on the R&D behind the IP and who paid for it. Acquired IP and related-party outsourcing reduce the qualifying share. Your engineering team does not automatically have to move: developers you employ, or can relocate and hire. We establish the position before designing the operating model.
Three questions. Thirty seconds.
- Did your company fund the development of its own software?
- Does that software earn income, licensed or embedded in what you sell?
- Would you put development and decision-making in Cyprus?
0 of 3 answered
Answer all three. The verdict updates as you go, and it will tell you if this is not for you.
One call tells you whether yours qualifies.
€120k
stays in your business. Every year.
- €150,000
- at the standard 15% rate
- €30,000
- under the IP Box.
Illustrative. A regulated Cyprus tax advisor quantifies your number in a formal opinion before you commit to anything.source
Article 9(1)(l) Income Tax LawUnchanged by the 2026 reformThe effective rate is a floor. It applies to the qualifying share of profit, which follows the OECD nexus rule: the R&D expenditure behind the IP and who incurred it. A smaller qualifying share moves the rate up, never down.Company tax is one number. Cyprus dividend tax decides what reaches you.
Corporate tax at 15%, on the 20% of qualifying profit that remains after the 80% deduction, then the dividend route out.source
SDC Law as amended by Law 245(I)/20251 January 2026Cyprus tax only. Your country of residence may tax the same dividend when you receive it, and that is the first thing a regulated Cyprus tax advisor will test against where you actually live. Illustrative, on the assumptions above, and not advice on your facts.
- Non-domiciled shareholder
- €965,230
- No SDC on dividends while non-dom status holds. GHS applies at 2.65% to the annual ceiling on total income, not to each source separately.
- Cyprus-domiciled, profits earned from 2026
- €921,500
- SDC on dividends fell from 17% to 5% for profits earned from 1 January 2026.
- Cyprus-domiciled, profits earned before 2026
- €805,100
- Profits earned to 31 December 2025 keep the 17% rate, and only if distributed on or before 31 December 2031.
A structure has to workoutside the tax return.
Your bank has to understand it. Your PSP has to accept the counterparty. An investor or a buyer has to be able to follow the money through diligence. And when you take profit out, you need a clean record of where it came from.
The legal minimum notice before an account closes. Many banks give exactly that.
2 months
PSPs demanding an EU counterparty you don’t have
No EU leg
A company registered in a country it does not operate in is a familiar refusal
No substance
Partners passing on deals after one look at your structure
Lost deals
Registering a Cyprus company is administrative. Getting an account opened for it is not. BLK Group holds an electronic money institution licence, so the EU IBAN is arranged inside the group rather than hoped for afterwards. It is subject to onboarding and full KYC and AML, like any regulated account. Funds that cannot be evidenced cannot enter.
We build structures that prove your revenue to every bank, PSP and partner that asks.
Not a paper structure. A Cyprus company that actually works.
An indicative 8–12 week path. Your existing entities keep operating throughout.
The structure has real operating costs. Company administration, people, accounting, audit and substance all cost money. We model those costs against the tax benefit before you commit. If the economics don’t work, we’ll tell you.
First call & KYC
One call and a short document list. Then a straight answer on fit.
Independent tax opinion
Regulated Cyprus advisors put the structure and your number on paper.
Set-up & onboarding
Entities, IP and banking, and an office with staff on payroll and board control on the island.
Run & report
Books, payroll, VAT, payments and nexus records, under one roof.
Company services
Licensed corporate service provider: incorporation, directorship, substance.
Bookkeeping
Books, payroll, VAT and audit-ready files through our accounting company.
Banking & EMI
IBANs, multi-currency accounts and payment operations via our licensed EMI.
Crypto on/off-ramp
Regulated fiat-to-crypto conversion through our licensed exchange.
The licence isn’t a third party’s.It’s the group’s.
BLK Advisory Services is the advisory brand of BLK Group. When this page says we set it up, staff it, book it, bank it and run it, those aren’t partners we found. They are companies with the same owners. We design the structure; the group company that holds the permission executes it.
Payments & e-moneyThe group’s payments brand: accounts, FX and cross-border payments, operated by VIP Tech360 Ltd (Cyprus, HE463449).Payment services delivered by FCA-authorised and FCA-registered group entities (UK)
Crypto & digital assetsAccept crypto and stablecoins, settle to fiat, pay out cross-border and hold assets in institutional custody.Swiss operations AML-supervised through ARIF, a FINMA-recognised self-regulatory organisation
Asset managementDesigns and manages alternative investment funds for professional investors, and carries the regulatory wrapper and the governance.ATVP-registered alternative investment fund manager under ZUAIS (Slovenia)
TechnologyWhite-label wallets, payment gateway APIs, fraud prevention and the XGATE custody platform the group’s own brands run on.- You are here
Corporate advisoryPayments strategy, EU corporate setup, cross-border structuring, VAT/VIES oversight, receivables and M&A. The brand you are reading now.Holds no licence. Advises, then hands execution to the group company that does 
TechnologyThe engineering arm behind the group’s payment and digital-asset platforms.
Group entities are authorised, registered or supervised in the United Kingdom, Canada, Switzerland and Slovenia; status differs by entity and jurisdiction. ARIF supervision is anti-money-laundering supervision under the Swiss AMLA, not a FINMA prudential licence. BLK Advisory Services holds no licence of its own: it advises, and hands execution to the group company that holds the relevant permission.
BLK Advisory Services is not a licensed tax advisory or audit firm.
Know the tax position before you build around it.
BLK designs and runs the structure. The formal tax opinion, the nexus modelling and the tax reporting come from a regulated Cyprus tax advisor, independently, before implementation. We do not write them and we do not sign them.
Questions
Said plainly, before you ask
What is the Cyprus IP Box?
A Cyprus tax regime under which 80% of qualifying profit from self-developed intellectual property is deducted, leaving the remaining 20% taxed at the 15% corporate rate, for an effective rate of about 3%. It is OECD-compliant and built on the nexus rule, so the qualifying share depends on the qualifying R&D expenditure behind the IP and who incurred it.
What qualifies, and what does not?
Copyrighted software can qualify: platform code, game engines, trading bridges and proprietary tools. Brands, trademarks and other marketing IP are excluded. The regime is built around technology you wrote, not a licence you resell.
Do our developers have to move to Cyprus?
Not wholesale, but the Cyprus company has to be the one that develops and controls the platform. In practice that means a resident technical lead and a core engineering team approving releases locally, with the Cyprus company funding the work. Development it does itself, or outsources to unrelated third parties, counts toward the qualifying share; development recharged from group companies outside Cyprus does not. You bring the technical leadership; we handle payroll, contracts and the office.
We already own the IP elsewhere. Can we still use the regime?
Usually, and the IP is transferred in at an independent valuation. What you pay to acquire IP that already exists counts toward total development spend without counting toward the qualifying share, so it reduces the share of profit that gets the reduced rate. How that lands on your facts is set out by a regulated Cyprus tax advisor in a formal opinion, alongside your existing advisors, before anything moves.
Is approximately 3% guaranteed?
No. About 3% is the floor rather than a promise: it is what the regime produces when the qualifying share is at or near its maximum, and a smaller share moves the effective rate up, never down. That share follows the development spend behind the IP and who incurred it. A regulated Cyprus tax advisor quantifies your number in a formal opinion before you commit to anything.
Does 3% survive the global minimum tax?
While you run it, yes. OECD Pillar Two’s 15% minimum applies only to groups above €750m of consolidated revenue, and companies below that line keep the IP-Box rate. At exit it depends on the buyer: a smaller or PE buyer keeps the benefit, while a very large strategic may absorb you into its Pillar Two group and top the rate up to 15%.
What does it cost to run?
It depends on what the company has to do, and we will not post a number we would then have to qualify. The swing factors are whether you need substance in Cyprus or only a registered entity, whether the ownership chain is straightforward, whether you need banking and of what kind, and the ongoing bookkeeping, payroll, VAT and statutory audit every Cyprus company files. Tell us which of those you need and the quote follows the scope.
Who issues the tax opinion?
A regulated Cyprus tax advisor from BLK’s partner network. BLK Advisory Services is not a licensed tax advisory or audit firm and does not write or sign the opinion; it designs and runs the structure the opinion describes.
Insights
Written for the people who have to defend the decision.
Cyprus structuring, UK corporation tax and the banking that decides whether a structure is worth having. Sourced, and dated.
Book a call
Your platform earned it.Now structure it.
- Does your platform qualify?
- What would your number be?
- What does it cost to run?
On €1m of qualifying IP profit, €120,000 a year stays in the business. One call tells you whether yours qualifies.
