Wealth & Estate

Cyprus Non-Dom Tax Residency

Non-domiciled status, the 60-day and 183-day tests, and the resulting dividend position.

Overview

Two separate positions have to be established, and founders frequently secure one while assuming the other follows.

Residency determines that Cyprus taxes worldwide income. It is established either by spending more than 183 days in Cyprus in the calendar year, or by satisfying the four conditions of the 60-day rule, which since 1 January 2026 no longer includes a bar on being tax resident elsewhere.

Domicile determines whether Special Defence Contribution applies. A Cyprus tax resident who is not domiciled in Cyprus falls outside that charge on dividends and interest entirely. This is where the value sits for most founders.

Neither is created retrospectively. Both are measured across a calendar year, so a move begun in September affects the following year rather than the current one, and the arrangements that evidence each of them have to exist while the year is running.

What is included

  • Route selection between the 183-day and 60-day tests, modelled against intended travel
  • Where the 60-day route applies, establishing each of the four conditions: the day count, the limit on days in any other country, the Cyprus tie, and the permanent residence
  • Structuring the Cyprus tie through employment, a directorship or a business, on terms that hold for the whole year
  • Registration with the Tax Department and issue of a tax identification number
  • The non-domiciled claim, evidenced on domicile of origin and residence history
  • Day-count record keeping and the supporting evidence file
  • Departure jurisdiction review, including exit charges and trailing residence rules
  • Treaty tie-breaker analysis where another state maintains a competing claim
  • Tax residency certificate applications and annual personal tax filings
  • Modelling of the 17 of 20 year point and, where relevant, the paid extension

How Doviandi approaches this

The departure country is analysed first. Cyprus law governs only whether Cyprus taxes the income. Many jurisdictions apply exit charges, deemed disposals or trailing residence rules that survive a move, and those determine whether the relocation achieves anything at all.

The 60-day conditions are treated as evidence, not intentions. A directorship terminated in October fails the condition for the whole year. A short-let arrangement is not a permanent residence. We structure each condition so it holds for the full year and produces a record.

GESY is included in every figure. Non-domiciled status removes Special Defence Contribution and not the health contribution, which is charged at 2.65 percent up to a cap of 4,770 per year. A saving quoted without it overstates the benefit.

The end date is modelled at the start. The 17 of 20 year test is known years in advance, and the paid extension introduced in 2026 costs 50,000 per year. Whether it is worth taking is arithmetic we run against projected dividends rather than a decision left to the year it bites.

Background reading on the questions this service answers:

Engagement at a glance
Residency routesMore than 183 days, or the 60-day rule on four conditions from 2026
What non-dom removesSpecial Defence Contribution on dividends and interest
Dividend SDC if domiciled5 percent on profits earned from 1 January 2026
What it does not removeGESY at 2.65 percent, capped at 180,000 of total income
DurationUntil resident for 17 of the previous 20 tax years
Extension from 2026Two further five-year periods at 250,000 each

Ready to design your Cyprus structure?

Book a confidential consultation with Doviandi. We will review your corporate, IP, and residency position against the 2026 Cyprus tax framework.