Cyprus Imaging Centre Licensing: New Tax Residence Certificate Forms
- Aug 20
- 9 min read
Last legally reviewed: 20 August 2026. General information only; not legal or tax advice.
Direct answer: On 20 August 2026, the Cyprus Tax Department announced dedicated declaration forms for individuals who require a Cyprus Tax Residence Certificate as part of an Imaging Centre operating-licence application under Law 35(I)/2026. Separate forms apply to the commonly described 183-day and 60-day routes. The procedure is limited to the appointed administrative and/or scientific responsible person, and the certificate issued through this route will be expressly marked for submission to the Ministry of Health under that law.
Key points
This is a dedicated licensing procedure, not a new tax and not a new definition of Cyprus tax residence.
The applicant is the relevant natural person appointed as administrative responsible person and/or scientific responsible person, not the Imaging Centre company merely because it owns or operates the business.
The correct form is emailed to the Tax Department district office where the individual is registered, together with the evidence required by that form and a confirmation from the Imaging Centre of the person’s appointed role.
The resulting certificate is purpose-specific. It should not automatically be treated as a general certificate for treaty, banking, immigration, domicile or non-domicile purposes.
The certificate is one document within a much wider Ministry of Health licensing file and does not itself secure an operating licence.
What exactly has the Cyprus Tax Department announced?
The Tax Department announcement states that two dedicated forms have been uploaded: one for a certificate based on the 183-day rule and one for a certificate based on the 60-day rule. The forms are exclusively for a natural person’s certificate to be submitted to the Ministry of Health in connection with an Imaging Centre licensing application.
The applicant must send the relevant form by email to the Tax Department district office at which the individual is registered. The submission must include the supporting documents prescribed by the selected form and a confirmation from the Imaging Centre that the applicant is its administrative responsible person and/or scientific responsible person. The certificate will state that it is intended for the Ministry of Health for the purposes of Law 35(I)/2026.
This is best understood as an operational mechanism for satisfying an existing licensing requirement. It does not alter the statutory tests for individual tax residence and it should not be approached as a routine formality where the underlying residence facts are uncertain.
Why is a Tax Residence Certificate required for an Imaging Centre licence?
The requirement comes from section 9(2)(d) of Law 35(I)/2026. An operating-licence application must include a utility bill and a Cyprus Tax Residence Certificate for the administrative responsible person and the scientific responsible person. The same section requires a substantial wider dossier, including professional licences, the organisation chart and staff list, premises documentation, equipment evidence, planning and fire-safety documents, radiation approvals where applicable, and proof of payment of the prescribed application fee. The competent authority may also request further information or expert reports.
The law applies to Imaging Centres operating in Cyprus in the private or public sector and whether located inside or outside a hospital. It distinguishes the administrative role, which concerns lawful organisation, management, staffing, installations, equipment and administrative compliance, from the scientific role, which carries the highest scientific and medical responsibility for safe and proper clinical operation.
Who should apply for the certificate?
The special procedure concerns the individual role-holder. It does not mean that every shareholder, director or beneficial owner of an Imaging Centre requires this certificate solely because of that corporate status. A director or shareholder will be affected only where that person is also formally appointed as the administrative responsible person or scientific responsible person.
The Tax Department uses the expression “administrative and/or scientific responsible person”. On a combined reading of the announcement, section 9 and section 12, this appears to recognise that the same scientific responsible physician may also act as the administrative responsible physician. Where two different individuals hold the two roles, each should be expected to provide the certificate required for that role. Where one individual lawfully holds both roles, the Imaging Centre’s confirmation should identify both capacities clearly. This is our reading of the provisions; unusual ownership, employment or multi-service structures should be confirmed with the competent authority before filing.
The role confirmation should be consistent with the Ministry of Health application, employment or services documentation, board or ownership records where relevant, and the actual day-to-day arrangement. A nominal or retrospective appointment made only to produce a document creates avoidable licensing and tax risk.
Which form applies: the 183-day route or the 60-day route?
The 183-day route
The form is commonly described as the 183-day form, but the current statutory wording treats an individual as Cyprus tax resident under this route where the person remains in Cyprus for periods that exceed 183 days in the tax year. In practical terms, exactly 183 counted days is not enough; the test normally requires at least 184 days, calculated under the statutory arrival and departure rules.
The 60-day route
The 60-day route is not satisfied by physical presence alone. Under the current consolidated Income Tax Law, the conditions are cumulative. The individual must not remain in any one other state for periods exceeding 183 days in the same tax year; must remain in Cyprus for at least 60 days; must carry on business in Cyprus, be employed in Cyprus and/or hold office in a Cyprus tax-resident person during the year, without that qualifying connection terminating during the year; and must maintain a permanent residence in Cyprus that is owned or rented by the individual.
The correct route is a legal and factual conclusion, not an administrative preference. Travel records, employment or office-holding evidence, the Cyprus home, tax-registration information and the position in any other country must tell one coherent story. Older online summaries of the 60-day rule should not be used without checking them against the current consolidated legislation and the form in force on the filing date.
How is the special application submitted?
Identify the individual who will hold each statutory role and confirm that the appointment is genuine and properly documented.
Determine which tax-residence route is actually satisfied for the relevant tax year.
Complete the dedicated 183-day or 60-day declaration form, rather than assuming that a general Tax Residence Certificate application is interchangeable.
Attach all evidence prescribed by the selected form. The supporting-document list should be taken from the current form itself and not reconstructed from general guidance.
Obtain a signed confirmation from the Imaging Centre identifying the applicant and stating whether the person is the administrative responsible person, the scientific responsible person, or both.
Email the complete application to the district Tax Department office where the individual is registered and retain the submitted package, delivery record and any acknowledgement.
Place the issued certificate into the wider Ministry of Health operating-licence file and verify that all names, roles, dates and supporting records are consistent.
The announcement does not state a special fee or guarantee a processing time for this certificate. General Tax Residence Certificate procedures should not be imported into this special route without confirmation. Separately, the three-month period in section 9(5) concerns examination of a complete operating-licence application by the competent licensing authority; it is not a promised Tax Department turnaround for the certificate.
What does the certificate prove—and what does it not prove?
The certificate records the Tax Department’s confirmation of the individual’s Cyprus tax-residence position for the relevant purpose and tax year, on the basis of the selected route and supporting evidence. In this special procedure, it will also state that it is intended for submission to the Ministry of Health under Law 35(I)/2026.
It does not, by itself:
grant or guarantee the Imaging Centre’s establishment or operating licence;
establish the tax residence of the Imaging Centre company or another legal entity;
prove immigration residence, permanent-residence status, citizenship, domicile or Cyprus non-domicile status;
resolve treaty residence where another country also treats the individual as resident; or
automatically serve as a general-purpose certificate for a bank, foreign tax authority, treaty claim or unrelated application.
Those questions may overlap in evidence, but they are legally distinct and should be analysed separately.
Timing for Imaging Centres already operating in Cyprus
The law was published in the Official Gazette on 23 March 2026. Under section 31, a person already providing imaging services when the law came into force may continue for 18 months, but must submit applications for establishment and operating licences within six months from commencement. On the face of the published law and assuming commencement on publication, that six-month point appears to fall on 23 September 2026. The precise computation, the status of any individual file and any later administrative direction should be confirmed directly with the Ministry of Health before reliance.
The Tax Department’s publication of the dedicated forms on 20 August 2026 does not state that it extends or restarts the statutory application period. Existing centres should therefore treat the role-holder certificates as an immediate workstream within the complete licensing dossier, rather than as an isolated tax form that can be addressed later.
Why accuracy matters
A responsible person should not sign a tax-residence declaration merely to remove a licensing obstacle. The evidence must support the chosen statutory route, and the Imaging Centre’s confirmation must reflect the real appointment. Where the person does not qualify under either route, the appropriate response is to review the appointment, employment and licensing structure lawfully—not to create an inaccurate declaration or artificial paper trail.
The risk is not theoretical. Under section 21 of Law 35(I)/2026, an operating licence may be revoked where it was issued contrary to the statutory conditions, where those conditions cease to exist, or where the licence or registration was obtained through fraud or false or inaccurate statements or representations. Separate tax consequences may also arise from an incorrect residence declaration.
Practical file review before submission
Confirm the exact legal name, tax identification number and district-office registration of each applicant.
Reconcile the statutory roles with the Ministry application, organisation chart, employment or services contract and corporate records.
Prepare a defensible day-count schedule for the whole tax year, supported by travel records rather than estimates.
Check the Cyprus business, employment or office-holding connection and the Cyprus permanent home where the 60-day route is used.
Review potential residence in another country and any tax-treaty issue separately.
Use the current dedicated form and its own evidence checklist; do not assume a prior general certificate package is sufficient.
Keep the Tax Department filing and the Ministry of Health licensing dossier consistent and preserve a complete audit trail.
Frequently asked questions
Is this a new Cyprus tax?
No. It is a dedicated procedure for obtaining evidence of an existing individual tax-residence status for a specific licensing requirement under Law 35(I)/2026.
Does the Imaging Centre company apply for this certificate?
No. The special Tax Department forms concern the natural person appointed as administrative responsible person and/or scientific responsible person. The company or other licence applicant still submits the wider Ministry of Health licensing dossier.
Does every director or shareholder need one?
Not solely because the person is a director or shareholder. The requirement follows the statutory role. A director or shareholder who also holds one of the responsible-person roles will need to address it in that capacity.
Does the 183-day form mean that exactly 183 days is sufficient?
No. The statutory wording requires periods in Cyprus that exceed 183 days during the tax year, subject to the specific day-count rules.
Is spending 60 days in Cyprus enough for the 60-day route?
No. All statutory conditions must be met cumulatively, including the required Cyprus business, employment or office-holding connection and a permanent Cyprus home.
Can the same person hold both responsible-person roles?
Potentially. Section 12 expressly allows the scientific responsible physician also to act as the administrative responsible physician. The person must still meet all professional, employment, presence, experience and tax-residence requirements that apply to the actual services and structure.
Does the certificate guarantee the operating licence?
No. It is one supporting document in a broad statutory dossier. The competent authority must be satisfied that all licensing conditions are met and may request additional information or expert evidence.
Can the certificate be reused for another purpose?
It should not be assumed. The Tax Department says the certificate issued under this process will be marked for submission to the Ministry of Health under Law 35(I)/2026. A separate general or purpose-specific certificate may be required elsewhere.
What if the proposed responsible person does not qualify under either residence route?
The person should not sign an inaccurate declaration. The Imaging Centre should obtain coordinated legal and tax advice on the role-holder appointment, employment and licensing structure before filing.
What is the apparent deadline for an existing Imaging Centre?
Section 31 requires applications within six months from commencement. On the face of the law published on 23 March 2026, the date appears to be 23 September 2026, but the computation and any later Ministry direction should be confirmed for the particular file.
How Cyprus Law Chambers can assist
Cyprus Law Chambers can review the statutory licensing matrix, the appointment and documentation of the responsible persons, corporate and employment records, the consistency of the Tax Department and Ministry of Health files, and the legal issues arising from Law 35(I)/2026. Where tax computations, foreign residence, treaty analysis or tax filings are involved, the work should be coordinated with the individual’s accountant or suitably qualified tax adviser.
For an initial file review: law@papacleovoulou.com | +357 26 933218
Primary sources
Cyprus Tax Department announcement dated 20 August 2026 on the dedicated Tax Residence Certificate forms.
Law 35(I)/2026 as published in the Official Gazette on 23 March 2026.
Sections 9, 12, 21 and 31 of Law 35(I)/2026.
Current consolidated Cyprus Income Tax Law, including the individual tax-residence definition.
Ministry of Health notice dated 6 May 2026 inviting Imaging Centres to submit licensing applications.
Tax Department announcement | Official Gazette text | Operating-licence requirements | Responsible-person provisions | Transitional provisions | Income Tax Law | Ministry of Health notice
Important notice
This publication is for general information and reflects the sources reviewed as at 20 August 2026. It does not constitute legal or tax advice. Tax residence, treaty residence and licensing outcomes depend on the relevant tax year, the individual facts, the evidence, the final form in force, administrative practice and any subsequent amendment, circular, extension or guidance. Specific advice should be obtained before any declaration, appointment or licensing submission is made.
