| Criterion | Cyprus | Malta |
|---|---|---|
| EU / euro | EU since 2004, euro area since 2008 | EU since 2004, euro area since 2008 |
| Corporate tax (standard rate) | 15% | Higher headline rate with a refund mechanic depending on the model; review in the specific case |
| IP / patent box | 80% deduction, 3% effective on qualifying IP profits after review | Its own IP regime; not the same mechanic as Cyprus |
| Language / law | English, common-law shaped | English, its own company law |
| Substance | Management and control, local director with documented duties | Its own substance and governance requirements |
| Relocation | 60-day rule and non-dom as a personal layer, separate from the Ltd | Its own residence and non-dom setting |
Takeaway
Cyprus fits projects with potentially qualifying IP (3% effective after review), manageable governance in Larnaca and DACH-facing support. Malta remains relevant where existing Malta structures, particular fund or gaming ecosystems, or a different personal residence model dominate. This is a structuring choice, not a ranking.
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