August 22, 2026
2 min read
Andreas Georghadjis LLC
The position from 2026: the conditions, the 2026 amendment and why a foreign tax-residence certificate is not enough.
The conditions
All four requirements must be satisfied during the same calendar year.
- Presence in Cyprus
- At least 60 days in Cyprus during the tax year.
- Presence elsewhere
- No more than 183 days in any single other country.
- Cyprus activity
- Business or employment in Cyprus, or an office in a Cyprus tax-resident person, such as a company directorship.
- Permanent home
- A home in Cyprus owned or rented by the individual.
The qualifying business, employment or office must not be terminated during that tax year.
What changed in 2026?
From 1 January 2026, the requirement that an individual must not be tax resident in another state has been removed.
Previously, foreign tax residence could prevent the 60-day rule from applying. It no longer does so where all the remaining conditions are met.
The practical effect: a foreign tax-residence certificate does not, by itself, displace the Cyprus domestic residence test.
To fall outside the 60-day rule on the ground of time spent abroad, an individual must spend more than 183 days in one other country. This is distinct from merely being recognised as tax resident there.
Counting the days
Both residence tests use the following day-counting rules.
- Arrival in Cyprus
- In Cyprus
- Departure from Cyprus
- Outside Cyprus
- Arrival, then departure on the same day
- In Cyprus
- Departure, then return on the same day
- Outside Cyprus
Treaty residence remains separate
Where another jurisdiction also treats an individual as resident, any applicable double taxation treaty must be examined separately. Its residence rules may consider the permanent home, centre of vital interests and habitual abode. The wording of the particular treaty governs.
The practical task is an annual review of travel, accommodation and the qualifying Cyprus activity, supported by records and, where necessary, a separate treaty analysis.
General information only. The application of the rules depends on individual circumstances.