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

Answered by Jordan Onraet-Wells, Founder & Chartered Tax Adviser (CTA). Published 9 August 2026. Last reviewed 9 August 2026.

The short answer

One condition was removed. Until 31 December 2025 the 60-day rule had five conditions, including that you were not tax resident in any other country that year. The Cyprus tax reform, in force from 1 January 2026, deleted that fifth condition, so the rule now has four: at least 60 days in Cyprus, no more than 183 days in any other single state, a permanent home in Cyprus, and a Cyprus business, employment or directorship that is not terminated during the year. Dual residence is now resolved under the relevant double tax treaty instead.

The old fifth condition, that you must not be tax resident in any other country that year, was removed with effect from 1 January 2026; guides still listing five conditions are out of date.
Four conditions remain, all required in the same calendar year: at least 60 days in Cyprus, a 183-day ceiling in any other single state, a permanent home in Cyprus (owned or rented), and a Cyprus business, employment or directorship not terminated in the year.
Where dual residence now arises, the tie-breaker article of the applicable double tax treaty decides which country wins, rather than the Cyprus claim failing altogether.
The same reform raised the Cyprus corporate income tax rate from 12.5% to 15% and cut Special Defence Contribution on dividends for Cyprus-domiciled residents from 17% to 5%.
Meeting the 60-day rule still does nothing to end your UK residence, which the UK Statutory Residence Test decides entirely on its own terms.

The reform and what it deleted

The Cyprus tax reform package was approved by the House of Representatives on 22 December 2025, published in the Official Gazette on 31 December 2025, and took effect on 1 January 2026. For the 60-day rule the change is simple: a technical tax residence in another country no longer disqualifies you from claiming Cyprus residence. That helps people with messy, multi-country years, because one stray residence status elsewhere used to torpedo the whole claim. The four surviving conditions are unchanged and all must be met in the same calendar year, with Cyprus counting your arrival day as a day in Cyprus and your departure day as a day outside it.

Why the change cuts both ways for UK leavers

The removal is genuinely helpful, but it means Cyprus no longer even asks whether you are still UK resident. It will happily treat you as resident under the 60-day rule while HMRC simultaneously treats you as fully UK resident under the Statutory Residence Test, which looks only at your UK days and ties. If both countries claim you, the 2018 UK-Cyprus treaty tie-breaker works through a fixed cascade: permanent home, centre of vital interests, habitual abode, then nationality. Keep a UK home and family while collecting a Cyprus certificate and the tie-break will usually go to the UK, so the exit itself, often with split-year treatment, is still the part that decides your tax bill.

The wider 2026 package

The same reform made changes worth knowing as context: the corporate income tax rate rose from 12.5% to 15%, Special Defence Contribution on dividends for Cyprus-domiciled residents fell from 17% to 5% for profits earned from 2026, and SDC on rental income was abolished. The non-dom regime itself survived, still giving 0% SDC on dividends and interest for up to 17 years, now with a paid extension route for later years. If you are planning the move, the full picture is in our moving to Cyprus guide. Horizon handles the UK half of exactly this planning on fixed fees agreed upfront, and a free clarity call at /book is the quickest way to pressure-test your dates.

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Sources and further reading

This is general information for the 2026/27 UK tax year, not personal tax advice; speak to a Chartered Tax Adviser about your own position.

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