Two routes, and only two
For individuals, Article 2 of Income Tax Law 118(I)/2002 provides exactly two routes into Cyprus tax residency. There is no third — no minimum income, no investment, no certificate that substitutes for them.
The first route is pure counting: staying in Cyprus for one or more periods totalling more than 183 days in a tax year makes you resident. No further requirement, no home, no activity.
The second route is the 60-day rule — and it is narrower than its name suggests.
The 60-day rule as the statute puts it
Reading the statute pays off here, because the usual lists shift its structure. The text first states an entry requirement and then three conditions that must be met cumulatively.
The entry requirement: you must not stay in any single other state for one or more periods totalling more than 183 days in the same tax year.
| Condition | |
|---|---|
| αα | At least 60 days in Cyprus in the tax year |
| ββ | A business in Cyprus and/or employment in Cyprus and/or an office held in a person that is tax resident in Cyprus, at any time during the year |
| γγ | A permanent home in Cyprus, owned or rented by the individual |
Three conditions, then — not four and not five. The official English page lists four points because it counts the entry requirement among them: the same rule, a different way of counting.
The precision that is missing almost everywhere
Condition ββ is usually summarised as “business, employment or a directorship”. The statute is more exact: it requires an office held in a person that is tax resident in Cyprus.
A directorship in a company that is not itself Cyprus tax resident therefore does not satisfy the condition on the wording. In practice the two often coincide, because a company incorporated in Cyprus is generally resident under the same provision — but that is not guaranteed.
The trap that costs the whole year
The same paragraph carries a proviso that is easy to read past: condition ββ is treated as not met if the business, the employment or the office is terminated during the year.
The effect is retroactive and hits the entire tax year, not merely the period after it ends. Resign a directorship in November and, for that year, you were never resident under the 60-day rule — even if every condition held for ten months. The first route, through 183 days, carries no such proviso.
How days are counted
The statute sets out the counting itself, and it favours the taxpayer: a day with both arrival and departure counts as a day in Cyprus.
| Event | Counts as |
|---|---|
| Day of arrival | a day in Cyprus |
| Day of departure | a day outside |
| Arrival and departure on the same day | one day in Cyprus |
| Departure and return on the same day | one day outside |
What fell away in 2026
Until the end of 2025 the 60-day rule carried a further condition: you had to not be treated as tax resident in any other state. That condition no longer appears in the consolidated statutory text as amended to 2026, and the Tax Department page no longer lists it either.
That materially eases the route into Cyprus, but it removes nothing from the other state’s claim. Dual residency is now possible and is not resolved by Cyprus law, but by the tie-breaker in the applicable double taxation treaty — usually permanent home, centre of vital interests, habitual abode and nationality, in that order. What else the 2026 reform changed is in the overview of the tax reform.
Companies: two routes, and one is wider than assumed
For companies the same provision names two cases:
- A company whose control and management are exercised in Cyprus.
- A company incorporated in Cyprus under the Companies Law — unless a double taxation treaty provides otherwise.
The second case carries real weight and is usually stated too weakly. On the wording in force, a company incorporated in Cyprus is resident by virtue of incorporation alone, regardless of where it is actually managed. Holding a Cyprus Limited and running it from abroad does not give you a non-resident company; it gives you a resident one, taxable on worldwide income.
Redomiciling to Cyprus counts as incorporation. The statute makes this explicit: a company that has transferred its registered office or its seat to Cyprus is deemed to have been incorporated in Cyprus. How incorporation works and what the state charges for it is in the guide to forming a company.
The certificate: two forms, not one
Banks, the tax authority of the other state and withholding relief under a treaty all call for a tax residency certificate. The Tax Department’s current list of forms carries two of them, with different addressees:
| Form | For whom |
|---|---|
| T.D. 126 (2022) | Declaration for the purpose of issuing a tax residency certificate — individuals |
| T.D. 98 (2015) | Application for a tax residency certificate and questionnaires for legal persons |
Guides that simply say “apply using T.D. 126” or “apply using T.D. 98” address only one of the two groups.
What residency is not
Three things are routinely conflated, and each has its own regime:
- Not the Yellow Slip. The residence certificate for EU citizens is issued under the free-movement law by the migration authority. The two are independent of each other — detail in the guide to the Yellow Slip.
- Not domicile. For the Special Defence Contribution, Law 117(I)/2002 additionally requires a domicile in Cyprus. Someone resident but not domiciled pays no contribution on dividends and interest. Anyone resident for seventeen of the last twenty years is deemed domiciled. What the status gives you and what it leaves untouched is in the guide to non-dom.
- Not social insurance. Liability arises from employment or self-employment, not from residency — see the guide for self-employed people and employer costs.
Which filings follow from residency, and when they fall due, is in the tax deadlines.
What we could not verify
- When the company incorporation wording changed. Confirmed is the text in force, with the exception “unless a double taxation treaty provides otherwise”. The earlier wording, with the “not tax resident in another state” carve-out, is confirmed through secondary sources; we did not find the amending law between the two.
- The amending law that removed the fifth condition of the 60-day rule. Confirmed is that it is absent from the text in force and from the Tax Department page, and that the reform package took effect on 1 January 2026. Which of the six amending laws carries the deletion we could not read — the texts exist only in Greek.
- Processing time and fee for the residency certificate. No official page states either.
- Whether the certificate is applied for through Tax For All. Secondary sources say yes; the official list of forms carries both forms as PDFs.
- What evidence the Tax Department requires for the day count. Passport copies and travel logs are widely mentioned; we found no official list.