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

The newly combined tax team has already worked on thousands of joint client matters, leaders from McDermott Will & Schulte tell ITR
As AI becomes increasingly intuitive and idiot-proof, its tax applicability is becoming impossible to overstate
New data on public CbCR showed uneven adoption, as Singapore advanced pillar two compliance and firms expanded their tax capabilities
Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention
With a stark divergence between MNEs that prepared early and those rushing to catch up, advisers must remain agile with all manner of compliance risks
The EU agreed new cooperative and investigative measures to tackle VAT fraud, while Hungary faced legal action and Lavez Coutinho expanded its indirect tax team
The arrival of a team from Brazilian rival Costa Tavares Paes Advogados brings SiqueiraCastro’s tax headcount to seven partners and 30 associates
CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind
Gift this article