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Tax Regime Comparison 2026

ZEC vs Ireland vs Malta vs Cyprus —
Which EU Tax Regime is Best?

A complete, honest comparison of the leading European low-tax jurisdictions for entrepreneurs, startups and investors. Updated for 2026.

Full comparison table

Key criteria for businesses choosing a European tax jurisdiction.

CriterionZEC 🇪🇸Ireland 🇮🇪Malta 🇲🇹Cyprus 🇨🇾Portugal 🇵🇹
Corporate tax rate
ZEC offers the lowest headline corporate rate in the EU for qualifying companies.
4%12.5%5% (after refund)12.5%21% (NHR is personal)
VAT / Indirect tax
ZEC companies pay IGIC (7%) instead of VAT. Significantly lower on domestic transactions.
7% IGIC23% VAT18% VAT19% VAT23% VAT
EU member state
All jurisdictions are full EU members — access to single market, EU directives and tax treaties.
✓ Spain (EU)✓ EU✓ EU✓ EU✓ EU
EU Parent-Subsidiary Directive
0% withholding on dividends to EU parent companies under each national implementation of the Directive (minimum holding in the Directive: 10%; Spain exempts from a 5% holding kept for one year — art. 14.1.h, Non-Resident Income Tax Act).
✓ Applies✓ Applies✓ Applies✓ Applies✓ Applies
Minimum employees
ZEC requires local employment — this is substance, not just a tax structure. It also means real EU market presence.
5 (GC/TF) / 3 (other islands)None (tax only)None (tax only)None (tax only)N/A (personal tax)
Minimum investment
ZEC requires a modest minimum investment in fixed assets within 2 years.
€50,000–€100,000NoneNoneNoneN/A
Digital Nomad Visa
Spain's international remote-work visa (in force since 23 December 2022) applies in the Canary Islands. Employees holding it may only work for companies located outside Spain (art. 74 bis, Law 14/2013).
✓ Spain DNV (Law 28/2022)Limited / N/ANomad Residence✓ Digital Nomad✓ Digital Nomad
Non-Dom / NHR personal tax
Spain's Beckham Law allows qualifying expats to pay a flat 24% personal income tax for 6 years.
Beckham Law (flat 24%)Remittance basisNon-Dom (flat)60-day ruleNHR 20% (closing 2024)
Profit reinvestment deduction
The RIC (Reserva para Inversiones en Canarias) lets companies reduce their tax base by up to 90% of undistributed profits from Canary Islands establishments, provided the reserve is invested within three years from the accrual date of the tax for the year in which it is set up (art. 27, Law 19/1994).
90% (RIC)NoneNoneNoneNone
Set-up time
ZEC registration requires prior authorisation from the ZEC Consortium, which by law must be decided within two months of the application (art. 41, Law 19/1994), on top of standard company formation.
Formation + ZEC authorisation (statutory limit: 2 months)3–4 weeks4–6 weeks2–3 weeks3–5 weeks
OECD BEPS compliance
ZEC is explicitly approved by the EU as compatible with state aid rules and is OECD/BEPS compliant.
✓ Fully compliant✓ Pillar Two 2024⚠ Under review✓ Compliant✓ Compliant
Quality of life
Year-round spring climate, direct EU flights, low cost of living vs. Western Europe.
⭐⭐⭐⭐⭐ Canary Islands⭐⭐⭐⭐ Dublin⭐⭐⭐⭐ Malta⭐⭐⭐⭐ Limassol⭐⭐⭐⭐⭐ Lisbon/Porto

* Rates and rules correct as of April 2026. Tax law changes frequently — always verify with a qualified advisor.

Which regime suits your profile?

Different business models have different optimal jurisdictions.

SaaS / Tech startup

Best: ZEC

Low corp tax, RIC reinvestment deduction, real EU presence, Spanish talent pool.

Also consider: Ireland (talent), Malta (quick setup)

E-commerce / Amazon FBA

Best: Depends on the activity

Wholesale trade and trade intermediation (NACE 46) are on the list of eligible ZEC activities, but retail trade (NACE 47) is not (annex to Law 19/1994), so it depends on how the business is classified. Imports of goods by ZEC entities are exempt from IGIC (art. 47, Law 19/1994).

Also consider: Cyprus (VAT optimization)

Holding / Investment company

Best: Other jurisdictions

Pure holding and investment activities are not on the list of eligible ZEC activities (annex to Law 19/1994, art. 31.2.c), and the regime requires real local jobs and investment.

Also consider: Netherlands (participation exemption), Malta (6/7ths refund)

Digital nomad / Freelancer

Best: Portugal NHR or Cyprus

No employee requirement. Founders who want to build a company in the Canary Islands can consider the ZEC, but the remote-work visa is for remote work for companies outside Spain (art. 74 bis, Law 14/2013), so the residence permit must match your role in the company.

Also consider: ZEC (if hiring 5+ in Gran Canaria/Tenerife, 3+ on other islands), Spain Beckham Law

Manufacturing / Logistics

Best: ZEC

Manufacturing (NACE 10–33, with exceptions) and transport and storage (NACE 49–53) are on the list of eligible ZEC activities (annex to Law 19/1994).

Also consider: Ireland (pharma), Cyprus (shipping)

Ready to set up your ZEC company?

We handle the full process — from ZEC registration to banking setup and compliance. Your first consultation fee is deducted from our fees if you instruct us.

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Data controller: ALY Abogados (Lázaro Héctor Amable Méndez). Purpose: handling your enquiry. Rights: access, rectification and erasure at alyabogados@lazaroamable.com.

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