Non Domicile “The Cyprus Particular” Tax Class – Corporate Tax

13 May 2022

CYAUSE Audit Services Ltd

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A non-dom is someone who lives in a country but does not have

the same domicile as that country. Once an individual is born in a

particular country they automatically become domiciled in that

country, someone by changing the country of his residence is not

automatically a tax resident to have the non-domicile status in

Cyprus there are several requirements. 

According to the provisions of the Cyprus tax laws, an

individual who is a tax resident of Cyprus under the provisions of

the Income Tax Law (either under the 183

days rule or the 60 days rule) but is “non-domiciled”

in the Republic of Cyprus, and will be exempt from Special Defence

Contribution (SDC).

The 183-day rule for Cyprus Tax residency is for individuals who

reside 183 days in any one calendar year in Cyprus. The 60-day rule

for Cyprus Tax residency is for individuals who do not reside in

any state for more than 183 days, are not considered tax residents

in any state, reside in Cyprus for at least 60 days in a row, and

have other engagements with Cyprus. 

The Social Defence Contribution law states that dividends and

interest that are earned by individuals who are tax residents and

domiciled in Cyprus, are subject to tax at the rate of 17% and 30%

respectively regardless of the streaming of their income is coming

from Cyprus or abroad. The rent is also taxable at the rate of 3%

on 75% of the gross amount. The non-domiciled individuals on the

other hand will enjoy dividends, interest, and rental income

tax-free.

A person of Cyprus origin will be also treated as

”domiciled in Cyprus” for SCD purposes with the

exception of:

  1. If residing in a different country and has obtained a Domiciled

    Tax status and was not a Cyprus tax resident for at least 20

    consecutive years before the tax year in question
  2. An individual who was not a Cyprus tax resident for a period of

    at least 20 consecutive years immediately before the entry into

    force of the introduced provision. (before 16/07/2015)

In general, an individual who remains a tax resident of Cyprus

for at least 17 years out of the last 20 years before the tax year

in question, is considered to be domiciled for SDC

purposes. 

Benefits of Non-Domicile Status

  • Tax Benefits of the Non–Dom Status:
  • 100% Tax-Free Dividends
  • 100% Tax-Free Passive Interest Income
  • No Special Defence Tax on Rental Income
  • Taxed based on Cyprus Corporation Tax on their World-Wide

    income

Conditions for Non Domicile:

  1. Cyprus wants to attract wealthy people to come and reside in

    Cyprus, those people should not have been living in Cyprus for 17

    out of the last 20 continuous years
  2. They need to show that they have been living in Cyprus for more

    than 60 days haven’t been living in any other country for more

    than 183 days 
  3. They need to register in Cyprus as Tax residents. 
  4. They need to have a physical presence in Cyprus, they need to

    show a rental agreement or buy a residential property. 

The status offers an excellent opportunity for tax planning

optimization for foreigners who want to increase their savings. The

Cyprus program is a tax reform to attract more international

investors and wealthy private individuals.

Originally Published 04 April 2022

The content of this article is intended to provide a general

guide to the subject matter. Specialist advice should be sought

about your specific circumstances.

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