Why Cyprus

The personal case, and what your own country does about it

Three Cyprus provisions decide whether relocating here is worth doing, and they are set out below. What decides whether it works is the other half: what the country you are leaving does when you go. That half is mapped by origin country further down this page.

Structuring a company rather than moving personally? See the corporate case.

The figures

Tax on dividends for a non-dom resident
No Special Defence Contribution. GESY applies, capped
Duration of non-dom status
17 years
Routes to tax residence
183 days, or 60 days where four conditions are met
Tax on capital gains
Charged on Cyprus immovable property, not on gains generally
Foreign pension income
5 percent flat above 5,000 euro, or the ordinary bands, elected annually
Inheritance tax
None
Wealth tax
None

What Cyprus provides

Non-domiciled status

No Special Defence Contribution on dividends or interest

A Cyprus tax resident who is not domiciled in Cyprus is outside the Special Defence Contribution, which is the tax that would otherwise apply to dividends and interest. For a founder taking profit from their own company as dividends, this is the provision that does the work. Status runs for 17 years.

Cyprus non-dom status

The 60-day rule

Residence on 60 days, where four conditions are met

Cyprus offers a second route to residence alongside the ordinary 183-day test. It requires 60 days in Cyprus, no more than 183 days in any other single country, a Cyprus business, employment or directorship held through the year, and a permanent home in Cyprus owned or rented. The condition that you not be tax resident in another state was removed with effect from 1 January 2026.

The 60-day rule

Expatriate exemption

50 percent of employment income exempt above 55,000 euro

Article 8(23A) exempts half of employment income where annual remuneration exceeds 55,000 euro, for up to 17 years, for an individual who was not Cyprus tax resident in the 15 years before their first employment here. The threshold is tested annually, and the exemption applies to salary rather than dividends.

How the exemptions interact

What it does not do

Cyprus residence does not end the other country's claim

Becoming Cyprus tax resident is one half of a move. The other half is ceasing to be resident where you were, which is decided by that country under its own rules and is very often the harder half. This is the point at which most relocations actually fail.

See what your country does on exit

What your country does when you leave

Doviandi is a licensed Cyprus firm and states the Cyprus position on its own authority. It is not licensed to advise on the tax law of the countries below, so this table describes what regime exists in each and what to put to your own adviser there. That division is deliberate and it runs through every playbook.

Exit position, Cyprus treaty status and residence test by origin country
OriginOn ceasing residence thereTreaty with CyprusResidence decided by
United KingdomNo charge on departure itself. YesStatutory Residence Test, with split-year treatment
GermanyDeemed disposal of qualifying shareholdings. YesResidence or habitual abode, ended by deregistration
United StatesNone on moving. Applies only on formal expatriation. YesCitizenship, not residence
IsraelDeemed sale, with deferral to actual realisation. YesCentre of life, a facts and circumstances test
IndiaNone. YesDay count, with a resident but not ordinarily resident tier
NetherlandsProtective assessment on a substantial interest. YesFacts and circumstances, centred on personal ties
FranceExit tax above value thresholds, with deferral inside the EU. YesHome, principal residence, professional activity or economic interests
SwedenNo departure charge. A ten-year trailing claim instead. YesEssential connection, which can survive physical departure
NorwayExit tax on unrealised share gains, recently tightened. YesDay count and continued ties, with a multi-year unwind
SwitzerlandNone. YesRegistration and residence with the commune and canton
ItalyAn area of recent change. Confirm the current position. YesRegistration, domicile or residence for most of the tax year
SpainExit tax above high thresholds, with deferral inside the EU. YesMore than 183 days, or the centre of economic interests
PolandExit tax above a 4 million zloty threshold. YesCentre of personal or economic interests, or 183 days
LithuaniaNone on individuals. YesDeclared residence, day counts, or personal and economic interests
UkraineNone. YesDomicile, then centre of vital interests, then day count
South AfricaDeemed disposal of worldwide assets. YesOrdinary residence, or the physical presence test
AustraliaDeemed disposal, with an all-or-nothing deferral election. NoneOrdinary residence, domicile and the 183-day test
New ZealandNo general departure charge. NonePermanent place of abode, plus a 325-day absence

Australia and New Zealand have no double tax treaty with Cyprus in force. Every other playbook in this set relies on a treaty tie-breaker to resolve which country has the residence claim. Those two do not have one, which changes the analysis rather than preventing the move, and it is the first thing to raise with an adviser in either country.

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.