Cyprus: Tax department clarifies 60-day rule for nominee directors

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cyprus: Tax department clarifies 60-day rule for nominee directors

intl-updates-small.jpg

Under the 60-day rule in Cyprus, individuals are considered tax residents of Cyprus and benefit from the island's tax regime.

They benefit if they:

  • Reside in Cyprus for a period of 60 days;

  • Do not reside in any other single country for a period exceeding 183 days;

  • Are not a tax resident in any other country;

  • Have commercial ties with Cyprus (i.e. are business owners, employees or directors) during the year in question; and

  • Are owners or tenants of a residential property in Cyprus.

Cyprus' tax department issued a circular on January 29 2019 to clarify a specific case. In the event of a nominee directorship, the tax department will deem that if the fourth condition has not been met, then tax residency status will not be obtained.

It is worth noting that the 183-day rule remains unchanged. This means that individuals can fulfil either the 183-day rule criteria or the 60-day rule criteria in the tax year, and if necessary, they can obtain the relevant certificate from the tax authorities.

more across site & shared bottom lb ros

More from across our site

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut
The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year
Gift this article