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


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.

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