Cyprus cross-border tax for tax year 2026 (Income Tax Law 118(I)/2002, SDC Law 117(I)/2002 and related laws on CyLaw). Covers individual residence (183-day rule and the 60-day rule), company residence (management and control, or incorporation in Cyprus), how non-residents are taxed on Cyprus-sour…
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Accountant-authored. Written and published by Ryan Duguid, an accountant approved on OpenAccountants. Their licence number is not on file. Their registration is in Australia; this skill covers Cyprus. General reference material, not advice on your specific facts; don't file, pay, or take a position on it without a professional reviewing your situation.
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| Item | Rate or amount | Year | Source |
|---|---|---|---|
| Individual resident: more than 183 days in Cyprus | more than 183 days | 2026 | Income Tax Law, art. 2: https://www.cylaw.org/nomoi/enop/non-ind/2002_1_118/full.html |
| 60-day rule: minimum days in Cyprus | at least 60 days | 2026 | Income Tax Law, art. 2 |
| 60-day rule: maximum days in any other single state | not more than 183 days | 2026 | Income Tax Law, art. 2 |
| Personal tax scale (residents and non-residents alike) | 0% to EUR 22,000; 20% to EUR 32,000; 25% to EUR 42,000; 30% to EUR 72,000; 35% above | 2026 onward | Income Tax Law, Second Schedule, para 1(c) |
| Corporate tax rate | 15% | 2026 onward | Income Tax Law, Second Schedule, para 2 |
| Exemption art. 8(21A): first employment in Cyprus, after 3 years employed abroad by a non-resident employer | 20% of pay or EUR 8,550, the lower; 7 tax years starting the year AFTER the employment year; starts up to 2027 | 2026 | Income Tax Law, art. 8(21A) |
| Exemption art. 8(21B): returning former residents | 25% of pay or business profit, max EUR 25,000 a year; pay above EUR 30,000; start year plus 6 years; starts 1 Jan 2025 to 2030 | 2026 | Income Tax Law, art. 8(21B) |
| Exemption art. 8(23A): first employment after at least 15 consecutive non-resident years | 50% of pay, for any year pay exceeds EUR 55,000; 17 tax years from the start year | 2026 | Income Tax Law, art. 8(23A) |
| Deductions for social insurance, GHS, pension and insurance: overall cap | 1/5 of taxable income before those deductions | 2026 | Income Tax Law, art. 14(2) |
| Termination payments above EUR 200,000 (residents and non-residents) | 20% on the excess, taxed separately | 2026 | Income Tax Law, art. 20ΣΤ |
| Royalties and technical assistance paid to a non-resident, right used in Cyprus | 10% of gross | 2026 | Income Tax Law, art. 21 ("δέκα σεντ κατά λίρα") |
| Royalties to an associated company in an EU-listed non-cooperative jurisdiction (if art. 21 did not already apply) | 10% of gross | 2026 | Income Tax Law, art. 21A(1) and (7) |
| Film rentals for showing films in Cyprus, paid to a non-resident | 5% of gross | 2026 | Income Tax Law, art. 22 |
| Non-resident individual: profession or vocation exercised in Cyprus; non-resident entertainers and sports teams performing in Cyprus | 10% of gross | 2026 | Income Tax Law, art. 23 |
| Non-resident: services in Cyprus on the continental shelf, natural resources and pipelines, not through a permanent establishment | 5% of gross | 2026 | Income Tax Law, art. 23A |
| Dividend to an associated company in a low-tax jurisdiction | 5% SDC | from 1 January 2026 | SDC Law, art. 3(1)(d)(i)(aa); commencement note to Law 48(I)/2025: https://www.cylaw.org/nomoi/enop/non-ind/2002_1_117/full.html |
| Dividend to an associated company in an EU-listed non-cooperative jurisdiction | 17% SDC (prevails if both) | 2026 | SDC Law, art. 3(1)(d)(i)(bb) |
| Interest to an associated company in an EU-listed non-cooperative jurisdiction | 17% SDC | 2026 | SDC Law, art. 3B(c) |
| Low-tax jurisdiction test | third country with a corporate rate below 50% of the Cyprus rate (below 7.5% at 15%) | 2026 | SDC Law, art. 2; Income Tax Law, art. 2 |
| Capital gains tax on Cyprus immovable property and on shares deriving value from it (residents and non-residents) | 20% | 2026 | Capital Gains Tax Law, art. 4: https://www.cylaw.org/nomoi/enop/non-ind/1980_1_52/full.html |
| Shares count as Cyprus property for CGT if held through other companies | at least 20% of their market value from Cyprus immovable property | 2026 | Capital Gains Tax Law, art. 2 ("ιδιοκτησία") |
| CGT lifetime exemption, individuals | EUR 30,000 | 2026 | Capital Gains Tax Law, art. 5(1) |
| Employee social insurance | 8.8% of insurable earnings | 2026 | Business in Cyprus (Government portal): https://www.businessincyprus.gov.cy/social-insurance-registration-and-contributions/ |
| Maximum insurable earnings, monthly-paid employees | EUR 5,742 a month from 1 January 2026 | 2026 | Social Insurance Services: https://sisweb.mlsi.gov.cy/anotato2025/ |
| GHS (GESY) contribution, employee | 2.65% of emoluments; income above EUR 180,000 is not charged | 2026 | General Healthcare System Law 89(I)/2001, art. 19(1)(a) and (4): https://www.cylaw.org/nomoi/enop/non-ind/2001_1_89/full.html |
| Late payment interest (public interest rate) | 3.50% a year | calendar 2026 | Decree K.D.P. 376/2025: https://www.cylaw.org/KDP/data/2025_1_376.pdf |
Source-cited draft: not reviewed by an accountant, not for filing.
Cyprus taxes on the calendar year. Residence is tested year by year, and the law has no split-year rule: a person is resident or non-resident for the whole year. All article numbers below are to the Greek consolidated texts on CyLaw, which include the 2025 reform laws (Income Tax Law amendments up to 67(I)/2026). CyLaw is not the official gazette.
This skill links to its siblings instead of repeating them:
cy-non-dom: domicile, the 17-of-20-years deemed domicile rule, the SDC exemption for non-doms and the article 3D lump sum. Read it for any question about SDC on an individual.cy-corporate-tax: the 15% rate, the company return, provisional tax and CFC rules.cy-transfer-pricing: arm's length pricing and the local file thresholds.cyprus-income-tax and cyprus-payroll: the personal return, PAYE and the T.D.59A.cyprus-social-contributions: social insurance and GHS rates in full.Individuals. An individual is resident in Cyprus for a tax year under either test (Income Tax Law, article 2, "κάτοικος της Δημοκρατίας", para (a)):
Day counting (article 2): the day of departure is a day outside Cyprus; the day of arrival is a day in Cyprus; arriving and leaving the same day counts as one day in Cyprus; leaving and returning the same day counts as one day outside.
Companies. A company is resident if (i) its management and control is exercised in Cyprus, or (ii) it is incorporated in Cyprus under the Companies Law, unless a double tax treaty provides otherwise. A company that moves its registered office or seat to Cyprus is treated as incorporated in Cyprus (article 2, para (b)). Law 244(I)/2025, article 2, added the incorporation test and the 2026 wording of the 60-day rule, in force from 1 January 2026 (Law 244(I)/2025, article 25). A Cyprus-incorporated company stays resident after its management moves abroad unless a treaty tie-breaker gives residence to the other state. Treaty tie-breakers are outside this skill; refer them.
Scope of the charge (article 5):
cy-non-dom.| Item | Rate or amount | Year | Source |
|---|---|---|---|
| Individual resident: more than 183 days in Cyprus | more than 183 days | 2026 | Income Tax Law, art. 2: https://www.cylaw.org/nomoi/enop/non-ind/2002_1_118/full.html |
| 60-day rule: minimum days in Cyprus | at least 60 days | 2026 | Income Tax Law, art. 2 |
| 60-day rule: maximum days in any other single state | not more than 183 days | 2026 | Income Tax Law, art. 2 |
| Personal tax scale (residents and non-residents alike) | 0% to EUR 22,000; 20% to EUR 32,000; 25% to EUR 42,000; 30% to EUR 72,000; 35% above | 2026 onward | Income Tax Law, Second Schedule, para 1(c) |
| Corporate tax rate | 15% | 2026 onward | Income Tax Law, Second Schedule, para 2 |
| Exemption art. 8(21A): first employment in Cyprus, after 3 years employed abroad by a non-resident employer | 20% of pay or EUR 8,550, the lower; 7 tax years starting the year AFTER the employment year; starts up to 2027 | 2026 | Income Tax Law, art. 8(21A) |
| Exemption art. 8(21B): returning former residents | 25% of pay or business profit, max EUR 25,000 a year; pay above EUR 30,000; start year plus 6 years; starts 1 Jan 2025 to 2030 | 2026 | Income Tax Law, art. 8(21B) |
| Exemption art. 8(23A): first employment after at least 15 consecutive non-resident years | 50% of pay, for any year pay exceeds EUR 55,000; 17 tax years from the start year | 2026 | Income Tax Law, art. 8(23A) |
| Deductions for social insurance, GHS, pension and insurance: overall cap | 1/5 of taxable income before those deductions | 2026 | Income Tax Law, art. 14(2) |
| Termination payments above EUR 200,000 (residents and non-residents) | 20% on the excess, taxed separately | 2026 | Income Tax Law, art. 20ΣΤ |
| Royalties and technical assistance paid to a non-resident, right used in Cyprus | 10% of gross | 2026 | Income Tax Law, art. 21 ("δέκα σεντ κατά λίρα") |
| Royalties to an associated company in an EU-listed non-cooperative jurisdiction (if art. 21 did not already apply) | 10% of gross | 2026 | Income Tax Law, art. 21A(1) and (7) |
| Film rentals for showing films in Cyprus, paid to a non-resident | 5% of gross | 2026 | Income Tax Law, art. 22 |
| Non-resident individual: profession or vocation exercised in Cyprus; non-resident entertainers and sports teams performing in Cyprus | 10% of gross | 2026 | Income Tax Law, art. 23 |
| Non-resident: services in Cyprus on the continental shelf, natural resources and pipelines, not through a permanent establishment | 5% of gross | 2026 | Income Tax Law, art. 23A |
| Dividend to an associated company in a low-tax jurisdiction | 5% SDC | from 1 January 2026 | SDC Law, art. 3(1)(d)(i)(aa); commencement note to Law 48(I)/2025: https://www.cylaw.org/nomoi/enop/non-ind/2002_1_117/full.html |
| Dividend to an associated company in an EU-listed non-cooperative jurisdiction | 17% SDC (prevails if both) | 2026 | SDC Law, art. 3(1)(d)(i)(bb) |
| Interest to an associated company in an EU-listed non-cooperative jurisdiction | 17% SDC | 2026 | SDC Law, art. 3B(c) |
| Low-tax jurisdiction test | third country with a corporate rate below 50% of the Cyprus rate (below 7.5% at 15%) | 2026 | SDC Law, art. 2; Income Tax Law, art. 2 |
| Capital gains tax on Cyprus immovable property and on shares deriving value from it (residents and non-residents) | 20% | 2026 | Capital Gains Tax Law, art. 4: https://www.cylaw.org/nomoi/enop/non-ind/1980_1_52/full.html |
| Shares count as Cyprus property for CGT if held through other companies | at least 20% of their market value from Cyprus immovable property | 2026 | Capital Gains Tax Law, art. 2 ("ιδιοκτησία") |
| CGT lifetime exemption, individuals | EUR 30,000 | 2026 | Capital Gains Tax Law, art. 5(1) |
| Employee social insurance | 8.8% of insurable earnings | 2026 | Business in Cyprus (Government portal): https://www.businessincyprus.gov.cy/social-insurance-registration-and-contributions/ |
| Maximum insurable earnings, monthly-paid employees | EUR 5,742 a month from 1 January 2026 | 2026 | Social Insurance Services: https://sisweb.mlsi.gov.cy/anotato2025/ |
| GHS (GESY) contribution, employee | 2.65% of emoluments; income above EUR 180,000 is not charged | 2026 | General Healthcare System Law 89(I)/2001, art. 19(1)(a) and (4): https://www.cylaw.org/nomoi/enop/non-ind/2001_1_89/full.html |
| Late payment interest (public interest rate) | 3.50% a year | calendar 2026 | Decree K.D.P. 376/2025: https://www.cylaw.org/KDP/data/2025_1_376.pdf |
Arriving individuals. Run the residence tests first. Then test the employment exemptions, which apply whether or not the person becomes resident (articles 8(21A), 8(21B), 8(23A) are framed on employment in Cyprus, not on residence; 8(21B) does need residence in each year after the start year). Only one can be used:
Older starts are under 8(21) (20%, starts 2012 to July 2022) and 8(23) (50%, pay above EUR 100,000, starts to July 2022). Refer those.
After the exemption, deduct social insurance, GHS, approved pension and insurance contributions, capped together at one fifth of taxable income before those deductions (article 14(2)). Social insurance paid to a fund set up in another EU state counts (article 14(1)(b)), and so does a contribution under a health system law comparable to the GHS in force outside Cyprus (article 14(1)(e)). Then apply the scale.
Non-resident individuals with Cyprus employment, rent or a permanent establishment file a return and pay on the scale (Assessment and Collection Law, art. 5(1)(b)). Professionals and performers fall under the 10% gross withholding in article 23 instead.
Non-resident companies pay 15% on profits of a Cyprus permanent establishment. A non-resident company whose whole Cyprus-source income was withheld under article 24 does not file (Assessment and Collection Law, art. 5(1)(d), first proviso).
Foreign tax credit. A resident taxed abroad gets a credit against the Cyprus tax on the same income: under a treaty (article 35), capped at the Cyprus tax on that income at the person's average rate, with claims within six years from the end of the tax year (article 35(3) and (9)); with no treaty, unilateral relief against the Cyprus tax on that income, capped at the foreign tax paid, following the article 35 procedure as far as practicable (article 36(1) and (2)). Foreign tax is not a deduction (article 35(5)(a)). SDC on foreign dividends and interest of a resident is reduced by the same credit (SDC Law, art. 4(4)).
Residents working abroad. Pay for employment exercised outside Cyprus for more than 90 days in the tax year, for a non-resident employer or a foreign permanent establishment of a resident employer, is exempt (article 36(5)). Profits of a foreign permanent establishment are exempt unless it is mainly investment income with a much lower tax burden, or it is in an EU-listed non-cooperative jurisdiction; the person can elect, for each foreign permanent establishment, to tax its profits with a credit instead (article 36(3) and (4)).
Leaving Cyprus: individuals. There is no exit tax on individuals. Article 33B applies only to a company or a permanent establishment. In the year of departure, residence turns on the day count: a person who spends 183 days or fewer in Cyprus and whose Cyprus employment ends in the year fails both tests and is non-resident for the whole year, taxed only on the Cyprus-source items above. Cyprus property stays inside CGT after departure (Capital Gains Tax Law, art. 4 taxes every gain on Cyprus property; residence is not a condition).
Leaving Cyprus: companies. Article 33B adds to income the difference between market value and tax value of assets when a resident company moves assets to a foreign permanent establishment, a Cyprus PE moves assets abroad, a resident company moves its tax residence abroad (assets left in a Cyprus PE are not caught), or a Cyprus PE's business moves abroad. Assets due to return within 12 months in a securities financing or collateral arrangement are excluded (article 33B(4)). The tax can be paid in instalments over five years, with interest, where the move is to an EU state or an EEA state with a recovery-assistance agreement (Assessment and Collection Law, art. 40A(1)). The instalments end at once if the assets or business are sold, moved on to a third country, the company goes insolvent, or it misses an instalment and does not cure it within 12 months (art. 40A(2)).
| Step | Deadline | Source |
|---|---|---|
| Withholding under articles 21, 21A, 22, 23, 23A: payer withholds from each payment and remits with a statement | by the end of the month after the month of withholding | Income Tax Law, art. 24(1) and (3) |
| Payer abroad, cost borne by a Cyprus associated person (articles 23 and 23A) | associated person remits by the end of the month after the month the cost is charged to it | Income Tax Law, art. 24(1A) |
| SDC withheld on dividends and interest | by the end of the month after the month the withholding was made or should have been made | SDC Law, art. 4(1A) |
| Individual return (resident, or non-resident with article 5(2) income) | 31 July of the year after the tax year | Assessment and Collection Law, art. 5(1)(a), (b) and (1A) |
| Company return, audited accounts | 31 January of the second year after the tax year (see cy-corporate-tax) | Assessment and Collection Law, art. 5(1A), first proviso |
| CGT on Cyprus property: disposal return and the tax | within one month of the disposal and before the transfer is registered | Capital Gains Tax Law, art. 12(1) |
| Foreign tax credit claim | within 6 years from the end of the tax year | Income Tax Law, art. 35(9) |
| Article 3D non-dom lump sum, SDC exemption form T.D.38 | see cy-non-dom | SDC Law, art. 3D |
cy-corporate-tax.cyprus-social-contributions.cy-transfer-pricing.Anna has never lived or worked in Cyprus. She arrives on 5 January 2026 and starts her first Cyprus job the same day at EUR 80,000 a year, paid in 12 equal monthly amounts. She spends 40 days abroad on trips during 2026.
Residence: 5 January to 31 December is 361 days counting the arrival day; less 40 days abroad gives 321 days. That is more than 183, so she is resident for 2026 under the 183-day rule.
Exemption: she has been non-resident for far more than 15 consecutive years and this is her first employment in Cyprus, started after 1 January 2022. Her first 12 months' pay exceeds EUR 55,000, so article 8(23A) exempts 50% from 2026, her start year: EUR 40,000. Article 8(21A) would give nothing in 2026 anyway, because it starts the year after the employment year.
Contributions: monthly pay of EUR 6,666.67 is above the EUR 5,742 ceiling, so social insurance is 8.8% of 12 x 5,742 = EUR 6,063.55. GHS is 2.65% of the full EUR 80,000 = EUR 2,120. Together EUR 8,183.55, but the deduction is capped at one fifth of the EUR 40,000 taxable income: EUR 8,000. Chargeable income is EUR 32,000. Tax: nil on the first EUR 22,000 and 20% on EUR 10,000 = EUR 2,000.
name: Anna, arrives 5 Jan 2026, EUR 80,000 salary, art. 8(23A) 50% exemption
inputs:
days_from_arrival: 361
days_abroad: 40
salary: 80000
si_ceiling_month: 5742
months: 12
steps:
- days_in_cyprus: days_from_arrival - days_abroad
- exemption_50: salary * 0.50
- taxable_before_deductions: salary - exemption_50
- social_insurance: min(salary, si_ceiling_month * months) * 0.088
- ghs: salary * 0.0265
- contributions: social_insurance + ghs
- one_fifth_cap: taxable_before_deductions / 5
- deduction: min(contributions, one_fifth_cap)
- chargeable: taxable_before_deductions - deduction
- tax: max(0, min(chargeable, 32000) - 22000) * 0.20 + max(0, min(chargeable, 42000) - 32000) * 0.25 + max(0, min(chargeable, 72000) - 42000) * 0.30 + max(0, chargeable - 72000) * 0.35
expected:
days_in_cyprus: 321
exemption_50: 40000
taxable_before_deductions: 40000
social_insurance: 6063.552
ghs: 2120
contributions: 8183.552
one_fifth_cap: 8000
deduction: 8000
chargeable: 32000
tax: 2000
Delta Ltd, a Cyprus resident company, pays two amounts in March 2026.
First, a royalty of EUR 120,000 to an unrelated foreign company with no business in Cyprus, for a trademark used in Cyprus. No treaty and no EU directive applies. Article 21 taxes it at 10% of gross: Delta withholds EUR 12,000, pays EUR 108,000 and remits the EUR 12,000 by 30 April 2026 (article 24). Article 21A does not apply: the recipient is not associated, and article 21A does not apply where article 21 tax was already withheld.
Second, a dividend of EUR 300,000 to its 100% parent, resident in a jurisdiction on Annex I of the EU list. The parent is associated, so SDC Law article 3(1)(d)(i)(bb) charges 17%: Delta withholds EUR 51,000 and pays EUR 249,000. The 17% applies even if the jurisdiction is also low-tax. The SDC is due by 30 April 2026 (SDC Law, art. 4(1A)).
Edge case: Delta remits the SDC in May 2026, late. It owes a 5% charge of EUR 2,550 (SDC Law, art. 7B(e)) plus interest at 3.50% a year from 30 April.
name: Delta Ltd, March 2026, art. 21 royalty and 17% SDC dividend to EU-listed parent
inputs:
royalty: 120000
dividend: 300000
steps:
- royalty_wht: royalty * 0.10
- royalty_net: royalty - royalty_wht
- dividend_sdc: dividend * 0.17
- dividend_net: dividend - dividend_sdc
- total_withheld: royalty_wht + dividend_sdc
- late_charge_sdc: dividend_sdc * 0.05
expected:
royalty_wht: 12000
royalty_net: 108000
dividend_sdc: 51000
dividend_net: 249000
total_withheld: 63000
late_charge_sdc: 2550
| Source | URL | Read on |
|---|---|---|
| Income Tax Law 118(I)/2002, consolidated to Law 67(I)/2026 (CyLaw), arts. 2, 5, 8, 14, 20ΣΤ, 21 to 24, 33B, 34 to 36, Second Schedule | https://www.cylaw.org/nomoi/enop/non-ind/2002_1_118/full.html | 2026-10-23 |
| Special Defence Contribution Law 117(I)/2002, consolidated (CyLaw), arts. 2, 3, 3B, 4, 7B | https://www.cylaw.org/nomoi/enop/non-ind/2002_1_117/full.html | 2026-10-23 |
| Assessment and Collection of Taxes Law 4/1978, consolidated (CyLaw), arts. 5, 40A, 50A | https://www.cylaw.org/nomoi/enop/non-ind/1978_1_4/full.html | 2026-10-23 |
| Income Tax (Amendment) (No. 4) Law 244(I)/2025, arts. 2 (residence definition), 24 (2026 scale) and 25 (in force 1 January 2026) | https://www.cylaw.org/nomoi/arith/2025_1_244.pdf | 2026-10-23 |
| Income Tax (Amendment) (No. 2) Law 47(I)/2025, arts. 4 to 8 (article 21 proviso deleted, article 21A, article 34(3), commencement) | https://www.cylaw.org/nomoi/arith/2025_1_047.pdf | 2026-10-23 |
| Income Tax (Amendment) Law 51(I)/2023, art. 2 (8(23A) look-back from 10 to 15 years) and art. 3 (in force from 1 January 2022) | https://www.cylaw.org/nomoi/arith/2023_1_051.pdf | 2026-10-23 |
| Capital Gains Tax Law 52/1980, consolidated (CyLaw), arts. 2, 4, 5, 12, 23A | https://www.cylaw.org/nomoi/enop/non-ind/1980_1_52/full.html | 2026-10-23 |
| General Healthcare System Law 89(I)/2001, consolidated (CyLaw), art. 19 | https://www.cylaw.org/nomoi/enop/non-ind/2001_1_89/full.html | 2026-10-23 |
| Decree K.D.P. 376/2025, public interest rate 3.50% for 2026 | https://www.cylaw.org/KDP/data/2025_1_376.pdf | 2026-10-23 |
| Social Insurance Services, maximum insurable earnings from 1 January 2026 | https://sisweb.mlsi.gov.cy/anotato2025/ | 2026-10-23 |
| Business in Cyprus (Government portal), social insurance contributions and posting of workers | https://www.businessincyprus.gov.cy/social-insurance-registration-and-contributions/ | 2026-10-23 |
| Regulation (EC) 883/2004, consolidated text, arts. 11 to 13 (EUR-Lex) | https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02004R0883-20190731 | 2026-10-23 |
Not yet confirmed: the jurisdictions on the EU Annex I list at each payment date (the Council page refused automated access); the Tax Department's own guidance pages on gov.cy (they refuse automated access and were not read for this skill); whether the second 5% late-payment charge in article 50A(e) also applies to article 24 withholding; any treaty rates.
Contributed by Ryan Duguid.
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