| Criterion | Cyprus | Estonia |
|---|---|---|
| EU | Yes, euro | Yes, euro |
| Tax logic | 15% on profits, IP Box 3% on qualifying IP profits | Tax mainly on distribution (retention is favoured) |
| Substance on the ground | Local director, management and control | Highly digital, e-Residency; local management is not the core promise |
| IP Box | Yes, with nexus and documentation | No Cyprus-style IP Box as a core offering |
| Relocation | Home, 60-day rule, non-dom | E-Residency is not residence |
Takeaway
Estonia fits when you need a lean, digitally run company without local management and you retain profits. Cyprus fits when IP qualification, personal residence, a director on the ground or a DACH tax nexus set the agenda. E-Residency does not replace substance in Cyprus, and the reverse is also true.
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