Cyprus: Tax department clarifies 60-day rule for nominee directors

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cyprus: Tax department clarifies 60-day rule for nominee directors

intl-updates-small.jpg

Under the 60-day rule in Cyprus, individuals are considered tax residents of Cyprus and benefit from the island's tax regime.

They benefit if they:

  • Reside in Cyprus for a period of 60 days;

  • Do not reside in any other single country for a period exceeding 183 days;

  • Are not a tax resident in any other country;

  • Have commercial ties with Cyprus (i.e. are business owners, employees or directors) during the year in question; and

  • Are owners or tenants of a residential property in Cyprus.

Cyprus' tax department issued a circular on January 29 2019 to clarify a specific case. In the event of a nominee directorship, the tax department will deem that if the fourth condition has not been met, then tax residency status will not be obtained.

It is worth noting that the 183-day rule remains unchanged. This means that individuals can fulfil either the 183-day rule criteria or the 60-day rule criteria in the tax year, and if necessary, they can obtain the relevant certificate from the tax authorities.

more across site & shared bottom lb ros

More from across our site

Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found
Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes
While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series
But partners at the firm admit that jumping ship to the US would not be as easy as some believe
Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created
Wingrove will succeed Bill Thomas, who has served in the role since 2017; in other news, Andersen unveiled a sharp increase in revenues for 2025
Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
Gift this article