Cyprus Tax Residency and Non-Dom in 2026: The 60-Day and 183-Day Rules
TAX RESIDENCE AND DOMICILE ARE DIFFERENT TESTS
Cyprus tax residence determines the income-tax framework that applies to an individual as a resident. Domicile is a separate concept used for Special Defence Contribution. A person can therefore be Cyprus tax resident and still qualify as non-domiciled if the statutory conditions are met.
THE 183-DAY RULE
An individual is Cyprus tax resident under the 183-day rule when they spend more than 183 days in Cyprus during the tax year. The statutory day-count rules determine how arrival and departure days are treated, so accurate travel records should be kept.
THE 60-DAY RULE IN 2026
The current 60-day route requires at least 60 days in Cyprus during the tax year, no more than 183 days in another single country, a Cyprus business, employment or office connection, and a permanent home in Cyprus that is owned or rented. From 2026, the former separate condition that the individual must not be tax resident in another country was removed. This makes dual residence more possible and increases the importance of treaty analysis where another country also treats the individual as resident.
THE CYPRUS CONNECTION MUST CONTINUE
For the 60-day rule, the business, employment or office connection needs to be considered for the relevant year. If that Cyprus connection ceases during the year, the statutory route may fail. The test should therefore be applied to the full factual timeline, not only to the intended number of days.
NON-DOM STATUS
Eligible Cyprus tax residents who are non-domiciled are generally outside Special Defence Contribution on dividends and interest. A deemed-domicile rule can arise where an individual has been Cyprus tax resident for at least 17 of the 20 tax years immediately preceding the tax year under review. Domicile should be checked separately from income-tax residence.
UK RESIDENCE STILL MATTERS
Becoming Cyprus tax resident does not automatically make a person non-UK resident. The UK Statutory Residence Test, possible split-year treatment and any UK-Cyprus treaty tie-breaker analysis should be considered separately. This is particularly important where a person retains a UK home, employment, business interests or significant time in the UK.
PRACTICAL RECORDS TO KEEP
Keep a reliable day-count, travel records, Cyprus tenancy or ownership evidence, employment or business records, director or office-holder evidence where relevant, and documents showing the timing of the move. These records may become important when tax residence or treaty residence is later questioned.
SPEAK TO OUR CYPRUS LEGAL TEAM
We can help coordinate the legal and residence workstreams and identify the Cyprus issues that should be taken to your tax adviser. Visit https://www.papacleovoulou.com/contact to request a consultation.
IMPORTANT
General information only. Tax residence, treaty residence and domicile depend on the facts for the relevant tax year and should be reviewed against current Cyprus and other applicable rules.
