News brief · Taxation

Cyprus: residency in 60 days still applies

Cyprus's sixty-day rule remains in force, but its four conditions are cumulative. It is their combination, not the length of presence, that makes the scheme hard to satisfy.

By Editorial team · on May 2, 2026

The four conditions

Cypriot law provides two routes to tax residency. The general rule is based on presence of more than less than 183 days¹ during the calendar year.

The so-called sixty-day rule allows a person to be tax resident with presence of only at least from 60 days², subject to four cumulative conditions.

Not staying more than one hundred and eighty-three days in any other state. Not being tax resident in any other state. Carrying on a business or holding a directorship in Cyprus. And having a permanent home there, owned or rented.

Failing a single one removes the benefit of the rule. It is this cumulative nature, not the sixty-day period, that makes it a demanding scheme.

The second condition is the hardest to meet. It requires not being tax resident anywhere else, which rules out most applicants who keep ties in their home country.

It should be noted that this rule is not an administrative concession but a statutory provision, which sets it apart from the informal arrangements practised elsewhere. It can therefore be relied on against the authorities, provided all its conditions are met and can be proven.

The burden of proof lies with the taxpayer. The documents — lease, utility bills, employment contract or directorship appointment, records of presence — are built up over the year, not at the time of an audit.

Who it is for

The rule targets a specific profile: a highly mobile business owner, with no tax residency elsewhere, who would otherwise not reach the residency threshold in any state.

It combines with Cyprus's non-dom status, which exempts passive income — dividends and interest — from the special defence contribution for 17 years³ of tax residency.

The exemption is not total: a contribution to the healthcare system remains due on this income at a rate of 2.65%⁴, up to an annual cap.

The income tax scale, applicable to earned income, ranges from 0%⁵ to 35%⁶. Gains on the disposal of securities are not taxed, at a rate of 0%⁷.

The deduction for first employment in Cyprus completes the picture: 50%⁸ of remuneration is deductible above an annual threshold of more than €55,000⁹.

What France can object

Cypriot tax residency does not remove the need to examine one's situation under French law. Article 4 B of the French General Tax Code uses the household, the main place of stay, the professional activity and the centre of economic interests as alternative criteria.

A business owner who kept their family home in France would remain domiciled there, and the France–Cyprus tax treaty would have to decide according to its own ranked criteria.

Sixty days of presence in Cyprus, combined with a family that has stayed in France, do not withstand this scrutiny. The rule is only of interest to those who genuinely have no ties anywhere else.

Even then, the treaty must be invoked, which requires the Cypriot tax residence certificate. Without it, dual residency cannot be resolved.

We do not publish the details of the announced relaxations of this rule or their effective date: we have not been able to verify them in an up-to-date official Cypriot source.

What to do

Check all four cumulative conditions, not just the length of presence.
Document the permanent home, owned or rented for the entire year.
Establish the role or activity carried on in Cyprus with documents: contract, directorship appointment, invoicing.
Make sure you are not tax resident in any other state.
Apply for the Cypriot tax residence certificate.

Cyprus's tax reform has also raised corporate tax to 15%¹⁰, from 12.5%¹¹ previously. For a business owner who receives income through a Cypriot company, it is the combined cost that counts, and it has gone up.

Please note

General information, as of the date shown. A draft reform is not a rule in force: check the conditions with the authorities or a professional before deciding. Terms of use and disclaimers

Sources and verification dates

1.
Cyprus: annual presence below which the general residency rule does not apply : 183 days
« According to Article 2 (“Definitions”) of the Income Tax Law of 2002 (Ν. 118(I)/2002), a natural person (individual) is considered a tax resident of Cyprus if they meet the criteria set out either under the 183-day rule or the 60-day rule. 183-day rule — An individual is considered to reside in Cyprus if they stay in Cyprus for one or more periods exceeding 183 days in total during a tax year. — Tax Department (Ministry of Finance), « Tax Residency/Domicility ». »
gov.cyVerified on Nov 2, 2026Verified source
2.
Cyprus: minimum annual presence under the so-called sixty-day rule : 60 days
« 60-day rule — An individual may be considered a tax resident of Cyprus even if they have not completed 183 days in Cyprus, provided that they meet all of the following conditions: They remain in Cyprus for at least 60 days during the tax year. They do not reside for more than 183 days during the year in another country. They carry on any business in Cyprus and/or are employed in Cyprus, whether as an employee and/or office holder. They maintain a permanent residence in Cyprus which they own or rent. — Tax Department, « Tax Residency/Domicility » (Income Tax Law N. 118(I)/2002, art. 2). »
gov.cyVerified on Nov 2, 2026Verified source
3.
Cyprus: period of tax residency after which a person is deemed domiciled : 17 years
« Furthermore, irrespective of the individual’s domicile of origin, any individual who has been a Cyprus tax resident for income tax purposes for at least 17 out of the last 20 years immediately before the tax year is deemed to acquire a domicile in Cyprus. […] Tax Consequences — Any individual who either: does not have a domicile in Cyprus (non-domiciled), or is not a Cyprus tax resident (non-resident) is not subject to Special Defence Contribution (SDC) on: rental income*; interest income; dividend income. — Tax Department, « Tax Residency/Domicility » (Special Defence Contribution Law N. 117(I)/2002). »
gov.cyVerified on Nov 2, 2026Verified source
4.
Cyprus: rate of the healthcare system contribution on passive income, at full effect : 2.65%
« Income earners (e.g. rent, interest, dividends) 1,70% 2,65% On their income »
gesy.org.cyVerified on Nov 2, 2026Verified source
5.
Cyprus: rate of the first income tax bracket : 0%
« DECLARATION FOR CLAIMING TAX DEDUCTIONS FOR THE TAX YEAR 2026 - Income Tax (By virtue of the Income Tax Law No.118(I) of 2002, as amended) — PART C. TAX COMPUTATION — Chargeable Income / Tax Rates : From 0 to 22.000 @ 0% ; From 22.001 to 32.000 @ 20 % ; From 32.001 to 42.000 @ 25 % ; From 42.001 to 72.000 @ 30 % ; From 72.001 @ 35 % — Tax Department, formulaire IR59 2026. »
gov.cyVerified on Nov 2, 2026Verified source
6.
Cyprus: top marginal income tax rate : 35%
« PART C. TAX COMPUTATION — Chargeable Income / Tax Rates : From 0 to 22.000 @ 0% ; […] From 42.001 to 72.000 @ 30 % ; From 72.001 @ 35 % — Tax Department, formulaire IR59 2026 (Income Tax Law No.118(I) of 2002, as amended). »
gov.cyVerified on Nov 2, 2026Verified source
7.
Cyprus: taxation of profits from the disposal of securities : 0%
« Tax wholly exempted income of: Profit from the sale of securities ; Dividends paid which are tax deductible from the paying co. ; Profits of a Permanent Establishment under certain criteria ; Gains relating to foreign exchange differences (forex) […] — Ministry of Finance, « Tax Incentives » (15 janvier 2026). »
gov.cyVerified on Nov 2, 2026Verified source
8.
Cyprus: share of remuneration deductible for a first employment in the Republic : 50%
« If you are claiming a deduction for first employment in the Republic you are allowed to deduct either (a) 20% of your emoluments from any employment with a maximum of 8.550, or (b) 50% of your emoluments from any employment provided that your salary exceeds 100.000 in the tax year according to circular 2017/4 (EE04), or (c) 50% of your emoluments from any employment provided that your salary exceeds 55.000 in the tax year according to circular 2022/10 and 2024/04. — Tax Department, formulaire IR59 2026, notes (Income Tax Law, art. 8(23A)). »
gov.cyVerified on Nov 2, 2026Verified source
9.
Cyprus: annual remuneration above which the first-employment deduction applies : €55,000
« (c) 50% of your emoluments from any employment provided that your salary exceeds 55.000 in the tax year according to circular 2022/10 and 2024/04. — Tax Department, formulaire IR59 2026, notes. »
gov.cyVerified on Nov 2, 2026Verified source
10.
Cyprus: corporate income tax rate resulting from the tax reform : 15%
« Φόρος πραγματικών μερισμάτων από 17% σε 5% · Κατάργηση λογιζόμενης διανομής μερισμάτων · Εταιρικός φόρος από 12,5% σε 15% · Κατάργηση τελών χαρτοσήμων · Stock Options: ειδικός συντελεστής 8% έως €1εκ./10ετία · Κρυπτοστοιχεία: αυτοτελής φορολόγηση 8% στο καθαρό κέρδος — Portail officiel de la Réforme fiscale 2026 (gov.cy/taxreform), « Avantages fiscaux pour les entreprises » (lois publiées au Journal officiel le 31 décembre 2025, en vigueur au 1er janvier 2026). »
gov.cyVerified on Nov 2, 2026Verified source
11.
Cyprus: former corporate income tax rate, before the tax reform : 12.5%
« Φόρος πραγματικών μερισμάτων από 17% σε 5% · Κατάργηση λογιζόμενης διανομής μερισμάτων · Εταιρικός φόρος από 12,5% σε 15% · Κατάργηση τελών χαρτοσήμων · Stock Options: ειδικός συντελεστής 8% έως €1εκ./10ετία · Κρυπτοστοιχεία: αυτοτελής φορολόγηση 8% στο καθαρό κέρδος — Portail officiel de la Réforme fiscale 2026 (gov.cy/taxreform), « Avantages fiscaux pour les entreprises » (lois publiées au Journal officiel le 31 décembre 2025, en vigueur au 1er janvier 2026). »
gov.cyHistorical value, applicable until January 1, 2026