Cyprus 60-day rule 2026: residence elsewhere no longer blocks it

The 2026 reform allows residence in Cyprus and elsewhere

In 2026, an individual can qualify under Cyprus’s 60-day route while resident elsewhere, according to Rightax, provided the remaining conditions are met. Treaty tests of available homes and closer personal and economic relations apply to an individual resident of both states.

For a UK leaver, the Statutory Residence Test considers UK ties alongside days spent there. For a German leaver retaining a dwelling, its continued availability and use matter under Germany’s domestic residence test.

Law 244(I)/2025, the Income Tax (Amending) (No. 4) Law of 2025, was published on 31 December 2025. Rightax states that the Cyprus tax reform removed the condition that the individual must not be tax resident in any other state.

Cyprus conditions are cumulative, and treaty tests run in order

The Cyprus conditions remain cumulative

For 2026, the Cyprus route requires at least 60 days in Cyprus during the tax year. Presence in any single other state must not exceed 183 days in aggregate during that same year. The 183-day limit is framed by reference to a single other state.

The individual must also carry on a business in Cyprus, be employed there, or hold office in a Cyprus tax-resident person. One qualifying connection is enough.

A permanent residence in Cyprus, owned or rented by the individual, is also required. Buying is not required. These conditions are cumulative: rented accommodation satisfies the housing requirement but does not replace the qualifying business, employment or office.

Treaty residence follows homes and personal and economic relations

For a dual resident under the UK–Cyprus treaty, a permanent home available in only one state determines treaty residence. Where homes are available in both, closer personal and economic relations determine the centre of vital interests. Habitual abode follows if that centre cannot be determined, or neither state has a permanent home available.

The Germany–Cyprus agreement reproduced in the Deutscher Bundestag government bill follows the corresponding sequence: permanent home, centre of vital interests, then habitual abode. Nationality follows, with mutual agreement between the competent authorities as the final stage.

Under both treaties, available homes and personal and economic relations remain decisive at the earlier stages.

Retained ties and UK departure rules can change the result

Homes and ties in the origin country still matter

For a founder, director or remote professional, qualifying in Cyprus is a separate question from ceasing to be resident elsewhere. The main beneficiaries are individuals who meet the Cyprus conditions while remaining resident in their origin country; their treaty position follows the sequence above.

A UK leaver’s retained ties must be considered alongside UK days: more ties mean fewer days before UK residence arises under the SRT.

For a German leaver, the dwelling test concerns the circumstances of retention and use. Under Germany’s Abgabenordnung, a Wohnsitz exists where an individual holds a dwelling in circumstances indicating that they will retain and use it.

UK tax exposure can continue after departure

The temporary non-residence rules require a period of sole UK residence followed by one or more residence periods without sole UK residence.

The prior-residence condition concerns at least 4 of the 7 tax years immediately before the departure year. Each qualifying year must involve sole UK residence throughout, or a split year containing a period of sole UK residence. The period of non-residence must be 5 years or less.

Inheritance Tax has a separate residence test from 6 April 2025. Foreign assets fall within scope for long-term UK residents: those resident for at least 10 of the 20 tax years preceding the chargeable-event year. That includes death.

After departure, individuals with 10 to 13 years’ residence remain in scope for a minimum of 3 tax years. Each additional residence year adds one tax year, up to a maximum of 10 tax years.

Four steps, each tied to a residence test

1. Before committing to a residence pattern: assemble a dated travel calendar, home ownership or tenancy records, and details of family locations and workdays. Individuals can collect these records themselves.
2. Before relying on Cyprus treatment: arrange an assessment of origin-country residence, followed by the treaty position. Supply evidence of each available home and personal and economic connections, rather than Cyprus days alone.
3. Before the tax year ends: review the continuing Cyprus business, employment or office against the conditions above. Assemble contracts, appointment records and any proposed termination dates for that review.
4. Before a disposal, distribution or planned UK return: arrange an individual assessment of departure-related exposure. Provide shareholding records, distribution plans and residence history before fixing transaction dates.

Individual UK or German residence and treaty outcomes depend on the relevant year's facts, including available homes and the centre of vital interests. Those conclusions, German exit tax and extended limited liability, and UK temporary non-residence and inheritance tax exposure require individual confirmation by a Cyprus-licensed tax adviser and either a UK chartered tax adviser (CTA) or a German Steuerberater, according to the origin country.

Send us your 2026 day counts, homes, work roles and UK or German ties so we can assess your residence position. We coordinate licensed Cyprus professionals who do the regulated work.