Cyprus tax residency
for Australians.

Cyprus earns its place on the anchor list as the EU base with the most founder-friendly combination in Europe: a 60-day residence route, a non-dom regime that removes Cypriot tax from dividends and interest, and no tax on gains outside Cypriot real estate. The 2026 tax reform, in force since 1 January 2026, changed several numbers that older guides, including Andersen’s, still state incorrectly.

Project Get Out researchUpdated 19 September 2026908 words

Key facts.

Tax model: PIT 0–35% · CGT most securities outside CGT, 20% on Cyprus real estate and property-rich interests, crypto gains 8% · CIT 15% · Tax basis: WW · SPECIAL: resident non-dom regime + 60-day residence route¹⁰
Australian DTA: No¹¹
Best fit: Made it | Making it | Make it in Crypto | Founder Planning Exit.
Tax law: Income Tax Law L.118(I)/2002 art 2 (residence); SDC Law L.117(I)/2002 (non-dom); CGT Law L.52/1980; consolidated texts via cylaw.org¹²
Tax residency certificate: Issued by the Cyprus Tax Department; available under both the 183-day and 60-day routes
PwC reference: taxsummaries.pwc.com/cyprus¹³

Two routes to residence, and the 60-day route just became easier.

An individual is Cyprus tax resident under either the 183-day rule, satisfied by more than 183 days of presence in the calendar year with no further conditions, or the 60-day rule. The 60-day rule requires, cumulatively, at least 60 days in Cyprus in the tax year, no more than 183 days in any other single state, a permanent residential property in Cyprus that is owned or rented, and a Cyprus business, employment or directorship of a Cyprus tax resident company that subsists at year end. Until the end of 2025 the rule also required that the individual not be tax resident anywhere else; that condition was removed with effect from 1 January 2026, which matters for a departing Australian, because a contested first-year Australian residency position no longer technically disqualifies the Cyprus claim. Day counting is mechanical: arrival day counts in, departure day counts out. For the Get Out sequencing point, the 60-day route makes Cyprus one of the few credible anchors compatible with substantial mobility, but the thinner the presence, the more the durability-of-association work in the Australian analysis has to be carried by the home, the directorship and the life actually built there.¹⁴¹⁵

Non-dom is the regime, and the 2026 reform left it intact.

Cyprus taxes residents on worldwide income at progressive rates reaching 35%, but a resident who is not domiciled in Cyprus is exempt from the Special Defence Contribution, which is the tax that would otherwise apply to dividends and interest. An Australian founder will almost always qualify, holding a foreign domicile of origin, and keeps the status until deemed Cyprus-domiciled after 17 of the preceding 20 years of residence. The 2026 reform sharpened rather than blunted the regime: SDC on dividends fell from 17% to 5% for domiciled residents on post-2026 profits, non-doms remain at 0%, SDC on rents was abolished, and the deemed dividend distribution rules were abolished for 2026 profits onward. What non-dom does not do: it does not touch the GESY health contribution of 2.65% on income including dividends and interest, capped at EUR 180,000 of income, roughly EUR 4,770 a year, and it does not shelter Cyprus-source employment or business income, which is taxed normally, subject to the separate 50% exemption for new first employments in Cyprus with remuneration above EUR 55,000, available for up to 17 years.¹⁶¹⁷¹⁸¹⁹

What an Australian pays, field by field.

Dividends and interest, foreign or Cypriot: 0% SDC as a non-dom, GESY only, up to the cap. Founder-share gains: outside Cyprus CGT entirely, because CGT at 20% applies only to Cyprus immovable property and to shares in companies deriving value from it, with the land-rich threshold reduced by the reform from more than 50% to 20% of value. Salary or business income earned in Cyprus: progressive rates to 35%, halved in effect where the 50% new-employment exemption applies. Foreign employment income for duties performed outside Cyprus for more than 90 days for a non-Cyprus employer can be exempt under the separate 90-day rule. Net wealth tax: none. Inheritance tax: none, and no gift tax between close relatives, although Cypriot succession law contains forced-heirship rules that an estate plan must navigate. There is no exit tax on individuals ceasing Cyprus residence, which keeps the second-exit cost low if the anchor is ever moved.²⁰

The Australian interaction, and the trap that undoes the structure.

Cyprus, like the UAE, has no comprehensive Australian treaty, so the same three consequences follow: no tie-breaker if the Australian exit is contested, full Australian domestic withholding on Australian-source unfranked dividends, interest and royalties, and a CGT event I1 decision made without treaty relief on either side. Two Cyprus-specific points complete the picture. First, the non-dom label answers a Cyprus question only; as the Guide’s FAQ explains, being non-domiciled in Cyprus neither helps nor hurts the Australian domicile test, which turns on whether the permanent place of abode is outside Australia. Second, and this is the trap, the 60-day directorship condition invites founders to become directors of Cyprus companies while still running an Australian operating company from Limassol. Cyprus determines corporate residence by management and control, so strategic decisions made from Cyprus can pull the Australian company, or a new holding company, into Cyprus corporate tax at 15%, while the ATO simultaneously argues central management and control never left Australia. The board, the decision record and the founder’s actual role need to be designed once, deliberately, for both systems.²¹²²²³

Trace the research

Sources and notes

These numbered notes are preserved from the supplied manuscript so each substantive statement remains connected to its research trail.

Cyprus tax reform package in force from 1 January 2026 (laws approved December 2025): CIT increased from 12.5% to 15%; SDC on actual dividends reduced from 17% to 5% for Cyprus resident and domiciled individuals for profits earned from 1 January 2026 (pre-2026 profits transitionally at 17%); deemed dividend distribution abolished for 2026 profits onward; SDC on rental income abolished; a flat 8% rate on qualifying crypto-asset gains introduced. See PwC Cyprus, The Cyprus Tax Reform, pwc.com.cy (accessed 24 August 2026). Verify the crypto provision against the enacted text before publication.↩
Australian Treasury, Income Tax Treaties (current list of comprehensive agreements given force of law by the International Tax Agreements Act 1953 (Cth)), treasury.gov.au/tax-treaties/income-tax-treaties (accessed 24 August 2026). The presence or absence of each jurisdiction is as stated in the relevant entry. A tax information exchange agreement is not treated as a DTA.↩
Cyprus Income Tax Law, L.118(I)/2002, art 2 (definition of "resident in the Republic"), as amended, including the 60-day rule introduced by L.119(I)/2017 and the amendment, effective 1 January 2026, removing the condition that the individual not be tax resident in any other state. Consolidated Greek text via cylaw.org; English translation to be hosted in the repository and linked before publication.↩
PwC, Worldwide Tax Summaries, Cyprus, Individual, Residence and Overview (last reviewed 4 August 2026), taxsummaries.pwc.com/cyprus (accessed 24 August 2026).↩
Cyprus Income Tax Law, L.118(I)/2002, art 2 (definition of "resident in the Republic"), as amended, including the 60-day rule introduced by L.119(I)/2017 and the amendment, effective 1 January 2026, removing the condition that the individual not be tax resident in any other state. Consolidated Greek text via cylaw.org; English translation to be hosted in the repository and linked before publication.↩
PwC, Worldwide Tax Summaries, Cyprus, Individual, Residence and Overview (last reviewed 4 August 2026), taxsummaries.pwc.com/cyprus (accessed 24 August 2026).↩
Special Contribution for the Defence of the Republic Law, L.117(I)/2002, as amended; the non-domicile exemption was introduced by L.119(I)/2015. An individual is deemed domiciled in Cyprus, notwithstanding a foreign domicile of origin or choice, once tax resident in Cyprus for at least 17 of the 20 tax years preceding the relevant tax year.↩
Cyprus tax reform package in force from 1 January 2026 (laws approved December 2025): CIT increased from 12.5% to 15%; SDC on actual dividends reduced from 17% to 5% for Cyprus resident and domiciled individuals for profits earned from 1 January 2026 (pre-2026 profits transitionally at 17%); deemed dividend distribution abolished for 2026 profits onward; SDC on rental income abolished; a flat 8% rate on qualifying crypto-asset gains introduced. See PwC Cyprus, The Cyprus Tax Reform, pwc.com.cy (accessed 24 August 2026). Verify the crypto provision against the enacted text before publication.↩
General Healthcare System Law, L.89(I)/2017: GHS (GESY) contributions of 2.65% for individuals apply to income including dividends and interest, capped at EUR 180,000 of income per annum (maximum approximately EUR 4,770).↩
Cyprus Income Tax Law art 8(23A): 50% exemption of remuneration from first employment exercised in Cyprus for individuals with annual remuneration exceeding EUR 55,000, available for up to 17 years, subject to conditions.↩
Capital Gains Tax Law, L.52/1980, as amended: 20% on gains from disposal of immovable property situated in Cyprus, or of shares in companies deriving value from such property; the 2026 reform reduced the land-rich value threshold from more than 50% to 20%. Verify final enacted threshold text before publication.↩
Australian Treasury, Income Tax Treaties (current list of comprehensive agreements given force of law by the International Tax Agreements Act 1953 (Cth)), treasury.gov.au/tax-treaties/income-tax-treaties (accessed 24 August 2026). The presence or absence of each jurisdiction is as stated in the relevant entry. A tax information exchange agreement is not treated as a DTA.↩
Australian domestic withholding on payments to non-residents, absent treaty reduction: unfranked dividends 30%, interest 10%, royalties 30% (Income Tax Assessment Act 1936 (Cth) Pt III Div 11A; Taxation Administration Act 1953 (Cth) Sch 1 Subdiv 12-F). Fully franked dividends are not subject to withholding.↩
Income Tax Assessment Act 1997 (Cth) ss 104-160 (CGT event I1) and 104-165 (choice to disregard); see Part V of the Guide for the full analysis.↩

Acronyms

What these terms mean.

PIT: personal income tax
CGT: capital gains tax
CIT: corporate income tax
DTA: comprehensive double tax agreement with Australia
WW: worldwide taxation
TERR: territorial taxation
REM: remittance basis
SPECIAL: preferential regime for qualifying new residents

Behind Project Get Out

Experience you can trace.

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