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 2025

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 UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
As World Tax unveils its much-anticipated rankings for 2026, we focus on EMEA’s top performers in the first of three regional analyses
Firms are spending serious money to expand their tax advisory practices internationally – this proves that the tax practice is no mere sideshow
The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
Former EY and Deloitte tax specialists will staff the new operation, which provides the firm with new offices in Tokyo and Osaka
Gift this article