Change of Tax Residency to Cyprus

For individuals:

The are two ways of establishing your Tax Residency: 183 days rule and 60 days rule. The first applies to the instances where an individual spends 183 days or more in Cyprus, whereas the last applies in cases when an individual spends in the Republic of Cyprus 60 days. Requirements apply to the 60 days rule that need to be fulfilled.

Please refer to our section of Tax Residency Certificate (TRC) for more information with respect to the application.

For companies:

In accordance with the Income Tax Law amendment, the definition of a “resident in the Republic” is enhanced so that a company established or registered under any applicable Law in Cyprus, which has its management and control exercised outside the country, is considered to be a resident of Cyprus, for tax purposes, unless such company is a tax resident in any other country.

The existing tax residency test, of management and control, will continue to apply. Therefore, a company that has its management and control in Cyprus will continue to be considered as a tax resident of Cyprus.

These changes are rarely achieved without cost. Some of the main issues at stake on a migration are listed below:

1. Sales taxes or stamp duty charges and registration charges on the sale and purchase of assets and the ‘stamping’ of documents, to ensure at least that the ownership of rights and assets are adequately protected in case of court proceedings. 
2. Compliance costs in gaining approvals from tax authorities towards a change of residence. Of particular concern to tax authorities is that any tax due should be adequately secure. 
3. Requirement to obtain consents from a state’s finance ministry. 
4. Exit charges. 

Our professional tax advisors can provide you guidance before making any decisions about changing tax residency and jurisdictions.