The provisions governing the 60-day tax residency rule for individuals in Cyprus have been amended as part of the Cyprus tax reform which entered into force on 1 January 2026.
Under the revised rule, the previous condition requiring that the individual must not be tax resident in any other state has been removed.
As a result, an individual may now qualify as a Cyprus tax resident under the 60-day rule even if they are simultaneously considered tax resident in another jurisdiction, provided that the remaining conditions of the rule continue to be satisfied.
This amendment simplifies the application of the rule and further enhances the attractiveness of Cyprus as a jurisdiction for internationally mobile professionals, entrepreneurs and investors.
What applied before 1 January 2026
Prior to the tax reform, individuals wishing to qualify as Cyprus tax residents under the 60-day rule had to satisfy five cumulative conditions.
In addition to spending at least 60 days in Cyprus during the relevant tax year, the individual also had to:
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not be tax resident in any other state,
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not spend more than 183 days in any other single country,
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carry on business in Cyprus, be employed in Cyprus, or hold a directorship in a Cyprus tax resident company, and
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maintain a permanent residence in Cyprus, whether owned or rented.
The requirement that the individual must not be tax resident in any other country was often considered restrictive for internationally mobile individuals who may be regarded as tax residents under the domestic rules of more than one jurisdiction.
The 2026 amendment removes this limitation, while maintaining all other conditions of the rule.
The remaining conditions of the 60-day rule
Following the amendment, an individual may qualify as a Cyprus tax resident under the 60-day rule if all of the following conditions are satisfied during the relevant tax year:
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presence in Cyprus for at least 60 days,
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no stay exceeding 183 days in any other single country,
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carrying on business, employment or holding a directorship in a Cyprus tax resident company, and
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maintaining a permanent residence in Cyprus during the year.
Interaction with double tax treaties
Where an individual is considered tax resident in more than one country under domestic tax rules, the final determination of tax residence may depend on the tie-breaker provisions of the relevant double tax treaty, where applicable.
Lead technical review: Kypros Kyprianou, Managing Director
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