Relocating a founder is not only a day-count exercise. Personal tax residence, company management, employment, permanent establishment, domicile and treaty residence can interact.
The 183-day route
An individual who is present in Cyprus for more than 183 days during the relevant tax year generally meets the domestic residence test, subject to the detailed day-count rules.
The 60-day route
The alternative 60-day rule requires all statutory conditions to be met. These include the relevant Cyprus presence, limits on time spent in another state, no tax residence elsewhere, a permanent home in Cyprus and the required business, employment or office connection.
Evidence file
- Passport and travel movement records;
- lease or title deed and utility evidence;
- employment, directorship or business documents;
- Cyprus tax and social-insurance registrations where relevant;
- banking and day-to-day expenditure records;
- board minutes and management records for controlled companies; and
- foreign tax-residence certificates or filings where relevant.
Company management and control
A founder moving to Cyprus may influence where strategic decisions for an overseas company are actually made. Board composition, decision-making, signing authority, office arrangements and the location of key functions should be reviewed rather than left to chance.
Dual residence and treaties
Domestic law can produce residence in more than one jurisdiction. The applicable double tax treaty may then apply tie-breaker criteria, and the supporting facts should be considered before taking a filing position.
Non-dom is a separate question
Cyprus non-domicile treatment should be analysed independently from tax residence. Eligibility depends on the statutory domicile rules and the individual’s history.
2026 update: from 1 January 2026, the former 60-day-rule condition requiring the individual not to be tax resident in another state was removed. Dual-residence and treaty tie-breaker analysis may nevertheless still be required.
Prepared by G. Adamides Audit Ltd. This article is general information, not advice for a specific fact pattern.