Cyprus 60-Day Rule Changes in 2026: What You Need to Know

Cyprus changed one important condition of the 60-day tax-residence rule from 1 January 2026. The old domestic requirement that an individual must not be tax resident in another country was removed. This creates more flexibility, but it does not make dual residence, double-tax treaties or evidence requirements disappear.

Last reviewed: 13 August 2026. This article provides general information only. Tax residence depends on the complete facts and any applicable double-tax treaty.

What changed in the Cyprus 60-day rule for 2026?

Before 2026, an individual using the Cyprus 60-day rule also had to show that they were not tax resident in another country during the same tax year. From 1 January 2026, that specific domestic condition no longer applies.

The amendment is relevant to internationally mobile individuals whose domestic residence position may overlap between Cyprus and another country. It does not, however, guarantee that Cyprus will be the individual’s only country of tax residence.

Key point: the amendment changes one Cyprus domestic-law condition. It does not override another country’s tax law or an applicable double-tax treaty.

Which 60-day conditions still apply?

The remaining conditions must still be reviewed for each calendar year. In broad terms, the individual must:

1. spend at least 60 days in Cyprus during the calendar year;
2. not spend more than 183 days in any other single country during that year;
3. carry on a business in Cyprus, be employed in Cyprus or hold an office in a Cyprus tax-resident company, subject to the applicable continuity conditions; and
4. maintain a permanent residential property in Cyprus that is owned or rented.

Spending 60 days in Cyprus is therefore only one part of the test. A short stay, a directorship or a tenancy agreement on its own is not enough.

What has not changed?

• The 183-day rule remains available: an individual who spends more than 183 days in Cyprus may qualify under that separate route.
• Day counting remains essential: time spent in Cyprus and every other country must be supported by reliable records.
• A genuine Cyprus connection is still required: the home and business, employment or office conditions remain important.
• Treaty residence can still be disputed: another country may also regard the individual as resident under its domestic law.
• Non-Dom status remains a separate analysis: tax residence does not automatically establish Non-Dom eligibility or make all income tax-free.

For a full comparison of the two routes, read our existing guide to the Cyprus 60-day and 183-day tax-residence rules.

Why dual tax residence still matters

Two countries can treat the same individual as tax resident under their own domestic rules. This can happen where a person moves during the year, keeps an available home in the departure country, retains close family or economic ties there, or continues to manage a business from more than one jurisdiction.

Where a double-tax treaty applies, its residence article may use tie-breaker tests to determine residence for treaty purposes. These commonly examine the permanent home, centre of vital interests, habitual abode and nationality. The wording of the relevant treaty and the individual’s complete facts must be reviewed.

Example: an individual connected with Germany and Cyprus

Assume an individual spends at least 60 days in Cyprus, satisfies the continuing Cyprus conditions and does not spend more than 183 days in Germany. The 2026 amendment may allow the person to meet the Cyprus domestic 60-day rule even if Germany also regards them as resident under German law.

That is not the end of the analysis. Article 4 of the Germany-Cyprus double-tax treaty considers where a permanent home is available and, if necessary, where personal and economic relations are closer. A German home, spouse or children, active business, employment and the place from which key decisions are made may all affect the conclusion.

Anyone planning a German departure should coordinate the Cyprus review with a German tax adviser before changing residence, transferring shares or restructuring an existing business. Our separate guide explains the main issues when moving from Germany to Cyprus.

Evidence to retain throughout 2026

A defensible residence position requires contemporaneous evidence. Depending on the circumstances, the file may include:

• a country-by-country travel schedule;
• boarding passes, tickets and passport movement records where available;
• a Cyprus title deed or properly executed tenancy agreement;
• utility bills and evidence that the Cyprus home is genuinely available and used;
• an employment contract, payroll records or evidence of Cyprus business activity;
• company appointment and corporate records where an office is relied upon;
• Cyprus and foreign tax registrations and filings; and
• evidence concerning homes, family ties and economic interests where treaty residence may be disputed.

Records should be assembled during the year rather than reconstructed after a filing deadline or certificate request.

Common misunderstandings about the 2026 amendment

• “Sixty days are enough”: the other statutory conditions still apply.
• “Dual residence no longer matters”: the amendment does not prevent another country from claiming residence.
• “A Cyprus certificate settles every country”: foreign domestic law and treaty tests still require review.
• “Non-Dom is automatic”: residence and domicile are separate concepts.
• “The company can be managed from anywhere”: company residence, permanent-establishment and substance risks require a separate analysis.
• “The change creates zero tax”: employment, business, pension, rental, dividend and interest income can receive different treatment.

Actions to take before relying on the 60-day rule

1. Prepare a travel forecast for Cyprus and every other country.
2. Identify each country that may claim domestic tax residence.
3. Review the relevant double-tax treaty.
4. Confirm that the Cyprus home and qualifying connection are in place for the required period.
5. Review all income sources, payroll, GHS and filing obligations.
6. Keep supporting evidence from the start of the year.
7. Coordinate the plan with an adviser in the departure country.

For a broader personal review, see our Cyprus tax-residency service and our guide to Cyprus Non-Dom status. The Cyprus Tax Calculator 2026 can also provide an indicative standard salary calculation.

Official sources

• Cyprus Tax Department – residence for tax purposes
• CySEC-hosted 2026 prospectus discussing the amended 60-day rule
• Business in Cyprus – income-tax registration and 2026 obligations

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APAFIOS assists international individuals and business owners with Cyprus tax-residence analysis, registration, compliance and coordination with related Cyprus company requirements.