United Kingdom → Cyprus
Advisor-ready analysis with claim-level citations and a sequenced execution plan.
The decision in figures.
Top personal income-tax rate
§ Cyprus - Individual - Taxes on personal income✓ verified 2026-07-16
For dividend (SDC rate of 17% for profits of tax years up to 2025, including certain grandfathering provisions or 5% for profits of tax years as from ...Open official source ↗
Capital-gains rate
Wealth tax
Inheritance tax
Exit tax
Claims with their evidence.
An individual will be UK resident for a tax year if they spend 183 days or more in the UK during that tax year, under both HMRC guidance and the First Automatic UK Test.
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
You’ll be UK resident for the tax year if you spend 183 days or more in the UK in the tax year. Open official source ↗
§ RFIG20320 - Statutory Residence Test (SRT): Automatic UK tests: First automatic UK test - HMRC internal manual - GOV.UK✓ verified 2026-07-16
An individual will be resident in the UK if they spend 183 days or more in the UK in the relevant tax year. Open official source ↗
Non-UK residence can be achieved under the Statutory Residence Test through several routes: fewer than 16 days in the UK if resident in any of the prior 3 tax years; fewer than 46 days if not resident in any of the prior 3 tax years; or fewer than 91 days (with under 31 working days) while working full-time overseas without a significant break.
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
You’ll be non-UK resident for the tax year if you were resident in the UK for one or more of the 3 tax years before the current tax year, and you spen...Open official source ↗
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
You’ll be non-UK resident for the tax year if you were resident in the UK for none of the 3 tax years before the current tax year, and spend fewer tha...Open official source ↗
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
You’ll be non-UK resident for the tax year if you work full-time overseas over the tax year and: you spend fewer than 91 days in the UK in the tax yea...Open official source ↗
A 90-day tie arises where an individual spent more than 90 days in the UK in either of the previous two tax years, and the deeming rule can apply where an individual has 3+ UK ties, was UK resident in one of the previous 3 tax years, and spends more than 30 days present in the UK without being present at midnight.
§ RFIG20570 - Statutory Residence Test (SRT): The ties test: 90-day tie - HMRC internal manual - GOV.UK✓ verified 2026-07-16
The individual will have a 90-day tie for the tax year if they have spent more than 90 days in the UK in either or both of the previous 2 tax years im...Open official source ↗
§ RFIG20720 - Statutory Residence Test (SRT): Days spent in the UK: The deeming rule - HMRC internal manual - GOV.UK✓ verified 2026-07-16
The deeming rule will apply to an individual for a tax year if they have: been UK resident in 1 or more of the 3 previous tax years · at least 3 UK ti...Open official source ↗
Cyprus tax residency under the 183-day rule is satisfied simply by spending more than 183 days in a calendar year in Cyprus, with no further conditions.
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ verified 2026-07-16
The '183-day rule' for Cyprus tax residency is satisfied for individuals who spend more than 183 days in any one calendar year in Cyprus, without any ...Open official source ↗
Cyprus tax residency can alternatively be established under the 60-day rule, which requires not residing elsewhere for over 183 days, not being resident elsewhere (condition removed from 2026), carrying out business/employment/directorship in Cyprus, and maintaining a permanent residential property in Cyprus.
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ verified 2026-07-16
The '60-day rule' for Cyprus tax residency is satisfied for individuals who, cumulatively, in the relevant tax year: do not reside in any other single...Open official source ↗
The UK Capital Gains Tax Annual Exempt Amount for the 2025/26 tax year is fixed.
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
This is GBP 3,000 for the 2025/26 tax year. Open official source ↗
Gains above the Annual Exempt Amount are taxed at the lower and higher CGT rates.
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
After this, gains are taxed at the lower and higher rates of 18% and 24%, respectively. Open official source ↗
Finance Bill 2024-25 legislation increased CGT rates for disposals made on or after 30 October 2024 for basic rate taxpayers, higher rate taxpayers, and trustees/personal representatives.
§ Capital Gains Tax — rates of tax - GOV.UK✓ verified 2026-07-16
Legislation will be introduced in Finance Bill 2024-25 amending sections 1H and 1I of Taxation of Chargeable Gains Act 1992 to increase: the 10% rate ...Open official source ↗
From the 2024/25 tax year onward, the Annual Exempt Amount has been permanently fixed for individuals/personal representatives and for most trustees.
§ Capital Gains Tax: Annual Exempt Amount - GOV.UK✓ verified 2026-07-16
For the tax year 2024 to 2025 and subsequent tax years the AEA will be permanently fixed at £3,000 for individuals and personal representatives, and £...Open official source ↗
The CGT proceeds reporting limit has also been fixed as part of the same measure.
§ Capital Gains Tax: Annual Exempt Amount - GOV.UK✓ verified 2026-07-16
The measure also fixes the CGT proceeds reporting limit at £50,000. Open official source ↗
Individuals who claimed the remittance basis in any of the 2017/18–2024/25 tax years may be eligible for rebasing of non-UK situs assets to their 5 April 2017 value, provided the assets were held outside the UK from 6 March 2024 to 5 April 2025, for disposals of non-UK assets post 5 April 2025.
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
For non-UK situs assets sold post 5 April 2025, individuals who made a claim for the remittance basis of taxation during any of the 2017/18 - 2024/25 ...Open official source ↗
The taxation of non-domiciled individuals in the UK changed significantly from 6 April 2025.
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
The taxation of non-domiciled individuals changed significantly from 6 April 2025. Open official source ↗
Under the former regime, individuals resident in the UK for at least 7 of the previous 9 years had to pay an annual remittance basis charge to retain access to the remittance basis.
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
In addition, if an individual had been resident in the United Kingdom in at least seven out of the previous nine years, the individual had to pay GBP ...Open official source ↗
This charge rose for non-domiciled individuals resident in the UK for 12 of the past 14 years.
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
This charge rose to GBP 60,000 for those non-domiciled individuals that had been resident in the United Kingdom for 12 out of the past 14 years. Open official source ↗
As of 16 July 2015, individuals not domiciled in Cyprus for Special Defence Contribution (SDC) purposes are exempt from SDC.
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
The following types of personal income are exempt from tax in Cyprus: As of 16 July 2015, individuals who are not domiciled in Cyprus for SDC purposes...Open official source ↗
An individual without a Cyprus 'Domicile of Origin' is only treated as domiciled in Cyprus for SDC purposes once resident there for at least 17 of the preceding 20 years.
§ Cyprus - Individual - Taxes on personal income✓ verified 2026-07-16
An individual who does not have ... for SDC purposes when the individual has been a tax resident of Cyprus for a period of at least 17 years out of th...Open official source ↗
For domiciled individuals, SDC applies instead of personal income tax on dividends and interest, with differing rates depending on income type and timing.
§ Cyprus - Individual - Taxes on personal income✓ verified 2026-07-16
For dividend (SDC rate of 17% for profits of tax years up to 2025, including certain grandfathering provisions or 5% for profits of tax years as from ...Open official source ↗
Cyprus General Healthcare System (GHS) contributions are capped based on annual income.
§ Cyprus - Individual - Other taxes - Worldwide Tax Summaries✓ verified 2026-07-16
GHS contributions are capped at EUR 180,000 annual income. Open official source ↗
For UK temporary non-residence purposes, a qualifying individual's total 'residence periods' that were not 'sole UK residence' must not exceed a specified length.
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
The total of the ‘residence periods’ that were not ‘sole UK residence’ did not exceed 5 years in length. Open official source ↗
Where the temporary non-residence conditions are met and the year of return to the UK is 2024/25, certain gains and losses arising during the period of non-residence are treated as arising in 2024/25.
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
If an individual whose year of return to the UK is 2024 to 2025 meets the conditions for temporary non-residence outlined above, then certain gains an...Open official source ↗
Such gains will be taxed, and losses will become allowable, in the year of return (2024/25 in the example given).
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
Such gains will therefore be taxed, with losses also becoming allowable, in 2024 to 2025. Open official source ↗
An individual who ceased UK residence in 2018/19 or earlier and does not resume UK residence until 2024/25 falls outside the scope of the temporary non-residence rules.
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
So, an individual who ceased to be UK resident in 2018 to 2019 or earlier and does not become UK resident again until 2024 to 2025 will not be within ...Open official source ↗
From 1 January 2022, a 50% exemption on remuneration applies to 'first employment' exercised in Cyprus by individuals not resident in Cyprus for at least 15 consecutive tax years before commencing employment.
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
As of 1 January 2022, a new 50% exemption on remuneration applies for 'first employment' exercised in Cyprus by individuals who were not resident in C...Open official source ↗
To qualify for the 50% exemption, employment must commence after 1 January 2022 and remuneration must exceed a minimum annual threshold.
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
The employment should commence after 1 January 2022, and the remuneration should exceed EUR 55,000 per annum. Open official source ↗
The 50% exemption applies once in an individual's lifetime, for a fixed duration.
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
For each individual, the exemption will apply once in their lifetime for a period of 17 years. Open official source ↗
From 26 July 2022, a 20% exemption on remuneration (subject to a maximum annual cap) applies to first employments in Cyprus commencing after that date, for individuals not resident in Cyprus for at least 3 consecutive years and previously employed abroad by a non-resident employer.
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
As of 26 July 2022, a new 20% exemption on remuneration (up to a maximum amount of exemption of EUR 8,550 per annum) applies for first employments com...Open official source ↗
The UK-Cyprus Double Taxation Convention was signed and subsequently entered into force.
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ verified 2026-07-16
Signed on 22 March 2018. Open official source ↗
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ verified 2026-07-16
This Convention entered into force on 18 July 2018. Open official source ↗
The Convention is effective for income tax and capital gains tax for years of assessment beginning on or after 6 April 2019, and for corporation tax for financial years beginning on or after 1 April 2019.
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ verified 2026-07-16
... (ii) For income tax and capital gains tax for any year of assessment beginning on or after 6th April 2019; and · (iii) For corporation tax any fin...Open official source ↗
An amending protocol to the Convention was signed on 19 December 2018 in Nicosia, entering into force on 2 October 2019 and effective in both countries from 1 January 2019.
§ Cyprus: tax treaties - GOV.UK✓ verified 2026-07-16
... An amending protocol to the UK and Cyprus Double Taxation Convention was signed on 19 December 2018 in Nicosia. Open official source ↗
§ Cyprus: tax treaties - GOV.UK✓ verified 2026-07-16
This entered into force on 2 October 2019 and is effective in both countries from 1 January 2019. Open official source ↗
UK Temporary Non-Residence Rules (TCGA92/S10A) — Exit Tax Exposure
TCGA92/S10A is designed to prevent a UK-resident taxpayer from avoiding Capital Gains Tax by leaving the UK, disposing of assets while non-resident, and then returning to the UK within a limited window. It applies where a UK resident leaves for up to five complete tax years and meets specified prior-residence conditions. Gains realised while non-resident can become chargeable in the year of return if the rules apply, with the split-year treatment interacting with the timing of departure and return.
- 01The individual must have had 'sole UK residence' for the whole or part of at least 4 out of the 7 tax years preceding the year of departure.
- 02The intervening 'residence period' that was not 'sole UK residence' must not exceed 5 years in total length.
- 03If the conditions are met and residence resumes in a given tax year, gains and losses arising during the non-residence period are treated as arising in the year of return and become chargeable/allowable at that point.
- 04An individual who ceased UK residence in 2018/19 or earlier and does not resume UK residence until 2024/25 falls outside the scope of these rules.
- 05The temporary non-residence period may start or end within a tax year due to split-year treatment.
- 06Staying non-resident (e.g. in Cyprus) for more than 5 full tax years takes the client outside S10A exposure entirely, making this the key planning threshold.
Exposure by holding.
| Asset | United Kingdom | Cyprus | Planning issue | Exit-tax impact |
|---|---|---|---|---|
| Listed shares (ordinary companies) | While UK resident, gains on disposal of listed shares are subject to UK Capital Gains Tax above the Annual Exempt Amount, at the applicable basic or higher rates. | In Cyprus, shares listed on any recognised stock exchange are excluded from Cyprus Capital Gains Tax, and dividend/interest income for non-domiciled individuals is generally exempt from Special Defence Contribution, though Cyprus Personal Income Tax applies to worldwide income for tax residents. | Timing of departure and disposal relative to UK residence status, split-year treatment, and the temporary non-residence rules under TCGA92/S10A determine whether gains crystallised while non-UK resident could later be taxed in the UK if residence resumes within the relevant window. | If the temporary non-residence conditions are met (sole UK residence for 4/7 years pre-departure, and a non-'sole UK residence' period not exceeding 5 years before resuming UK residence), gains on listed shares disposed of while non-resident are treated as arising in the year of return and become UK taxable at that point; remaining non-resident for more than 5 complete tax years removes this exposure entirely. |
UK-Cyprus Double Taxation Convention (2018, as amended)
The UK and Cyprus concluded a Double Taxation Convention in 2018, later amended by protocol, governing the allocation of taxing rights on income and capital gains between the two states, including specific provisions relevant to cross-border dividend income from certain property investment vehicles.
The Convention was signed on 22 March 2018 and entered into force on 18 July 2018.
It applies to income tax and capital gains tax for years of assessment beginning on or after 6 April 2019, and to corporation tax for financial years beginning on or after 1 April 2019.
An amending protocol was signed on 19 December 2018 in Nicosia, entering into force on 2 October 2019 and effective in both countries from 1 January 2019.
The Convention applies to taxes on income and capital gains imposed by either Contracting State or its political subdivisions/local authorities, irrespective of the manner in which they are levied.
A specific provision caps tax on dividends paid out of income derived from immovable property by certain investment vehicles at 15% of the gross dividend amount, other than where the beneficial owner is a pension scheme in the other Contracting State; the general dividend article rate applicable to ordinary portfolio shareholdings requires separate advisor confirmation.
A sequenced relocation roadmap.
- 01planning step
Confirm UK residence exit position under the Statutory Residence Test
Establish which non-residence route (16-day, 46-day, or full-time overseas work test) will apply for the departure tax year, and confirm split-year treatment implications for the year of departure.
- 02advisor workstream
Sequence share disposals around the departure date
Consider whether disposals of listed shares should occur before or after departure, factoring in the UK CGT Annual Exempt Amount and applicable rates, to optimise the tax position for the year of departure.
- 03advisor workstream
Assess exposure under the temporary non-residence rules (TCGA92/S10A)
Confirm the individual's UK residence history over the preceding 7 tax years to determine whether the 4/7-year 'sole UK residence' condition is met, and plan the non-residence period to avoid inadvertently falling within the 5-year window that would trigger UK taxation of gains realised abroad upon any return.
- 04planning step
Establish Cyprus tax residency
Determine whether Cyprus residency will be established under the 183-day rule or the 60-day rule, ensuring all conditions (including maintaining a permanent residential property and any Cyprus business/employment/directorship requirement under the 60-day rule) are satisfied from the outset.
- 05advisor workstream
Confirm Cyprus non-domicile status for SDC purposes
Verify eligibility for the Cyprus non-domicile exemption from Special Defence Contribution on dividend and interest income, noting the 17-out-of-20-year threshold at which non-domicile status would be lost.
- 06advisor workstream
Review UK non-dom rebasing eligibility
If remittance basis claims were made in any 2017/18–2024/25 tax year, assess eligibility for rebasing of non-UK situs assets to 5 April 2017 values for disposals after 5 April 2025.
- 07advisor workstream
Confirm treaty position under the UK-Cyprus DTA
Review the double taxation convention's effective dates and provisions, including the general dividend article applicable to portfolio shareholdings, to confirm relief from double taxation on any residual UK-source income.
- 08advisor workstream
Monitor the 5-year non-residence threshold
Track the departure and any prospective return dates carefully to ensure the temporary non-residence period exceeds 5 complete tax years if avoiding S10A exposure is the objective, or otherwise plan disposals within the constraints of the rules if an earlier return is contemplated.
Advisor checklist.
- 01
Confirm the interaction between UK SRT split-year treatment and the Cyprus 60-day rule day-counting conventions (midnight test vs departure/arrival test) in the transition year.
- 02
Confirm that the specific listed shareholdings fall outside UK 'property-rich' company or trading-asset exceptions that would otherwise bring non-resident disposals within UK CGT.
- 03
Confirm whether Cyprus imposes any wealth tax or general inheritance tax, as none was identified in the sources reviewed and this requires separate confirmation.
- 04
Confirm whether either Cyprus employment-income exemption (50% or 20% regimes) is relevant, given the client's stated income source is listed shares rather than employment income.
- 05
Confirm the general dividend article rate under the UK-Cyprus DTA applicable to ordinary portfolio shareholdings, as reviewed extracts covered only the special property-investment-vehicle provision.
- 06
Confirm the exact departure and (if any) return tax years to precisely fix the TCGA92/S10A temporary non-residence window.
- 07
Confirm whether any share disposals should occur before or after departure to manage exposure under the temporary non-residence rules if a return to the UK within five years is contemplated.
Dated source appendix.
- S01
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
This publication is available at https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-te...Open official source ↗
- S02
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
You’ll be UK resident for the tax year if you spend 183 days or more in the UK in the tax year. Open official source ↗
- S03
§ RFIG20320 - Statutory Residence Test (SRT): Automatic UK tests: First automatic UK test - HMRC internal manual - GOV.UK✓ verified 2026-07-16
An individual will be resident in the UK if they spend 183 days or more in the UK in the relevant tax year. Open official source ↗
- S04
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
You’ll be non-UK resident for the tax year if you were resident in the UK for one or more of the 3 tax years before the current tax year, and you spen...Open official source ↗
- S05
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
You’ll be non-UK resident for the tax year if you were resident in the UK for none of the 3 tax years before the current tax year, and spend fewer tha...Open official source ↗
- S06
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
You’ll be non-UK resident for the tax year if you work full-time overseas over the tax year and: you spend fewer than 91 days in the UK in the tax yea...Open official source ↗
- S07
§ RFIG20570 - Statutory Residence Test (SRT): The ties test: 90-day tie - HMRC internal manual - GOV.UK✓ verified 2026-07-16
The individual will have a 90-day tie for the tax year if they have spent more than 90 days in the UK in either or both of the previous 2 tax years im...Open official source ↗
- S08
§ RFIG20720 - Statutory Residence Test (SRT): Days spent in the UK: The deeming rule - HMRC internal manual - GOV.UK✓ verified 2026-07-16
The deeming rule will apply to an individual for a tax year if they have: been UK resident in 1 or more of the 3 previous tax years · at least 3 UK ti...Open official source ↗
- S09
§ RFIG22230 - Statutory Residence Test (SRT): supplementary guidance: exceptional circumstances: SRT day counting tests where exceptional circumstances cannot be taken into account when determining number of days spent in the UK - HMRC internal manual - GOV.UK✓ verified 2026-07-16
Days spent in the UK over the 60-day limit count as a day of presence for the purposes of the SRT. Open official source ↗
- S10
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ verified 2026-07-16
The '60-day rule' for Cyprus tax residency is satisfied for individuals who, cumulatively, in the relevant tax year: do not reside in any ot...Open official source ↗
- S11
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ verified 2026-07-16
The '183-day rule' for Cyprus tax residency is satisfied for individuals who spend more than 183 days in any one calendar year in Cyprus, without any ...Open official source ↗
- S12
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ verified 2026-07-16
The '60-day rule' for Cyprus tax residency is satisfied for individuals who, cumulatively, in the relevant tax year: do not reside in any other single...Open official source ↗
- S13
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ verified 2026-07-16
For the purposes of both the '183-day rule' and the '60-day rule', days in and out of Cyprus are calculated as follows: the day of departure from Cypr...Open official source ↗
- S14
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
This is GBP 3,000 for the 2025/26 tax year. Open official source ↗
- S15
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
After this, gains are taxed at the lower and higher rates of 18% and 24%, respectively. Open official source ↗
- S16
§ Capital Gains Tax — rates of tax - GOV.UK✓ verified 2026-07-16
Legislation will be introduced in Finance Bill 2024-25 amending sections 1H and 1I of Taxation of Chargeable Gains Act 1992 to increase: the 10% rate ...Open official source ↗
- S17
§ Capital Gains Tax: Annual Exempt Amount - GOV.UK✓ verified 2026-07-16
For the tax year 2024 to 2025 and subsequent tax years the AEA will be permanently fixed at £3,000 for individuals and personal representatives, and £...Open official source ↗
- S18
§ Capital Gains Tax: Annual Exempt Amount - GOV.UK✓ verified 2026-07-16
The measure also fixes the CGT proceeds reporting limit at £50,000. Open official source ↗
- S19
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
Non-UK resident individuals will not generally be subject to CGT, even if the asset disposed of is located in the United Kingdom. Open official source ↗
- S20
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
There are exceptions to this, however, such as UK trading assets, UK property (residential and commercial) / 'property-rich' companies, and carried in...Open official source ↗
- S21
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
For non-UK situs assets sold post 5 April 2025, individuals who made a claim for the remittance basis of taxation during any of the 2017/18 - 2024/25 ...Open official source ↗
- S22
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
The taxation of non-domiciled individuals changed significantly from 6 April 2025. Open official source ↗
- S23
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
In addition, if an individual had been resident in the United Kingdom in at least seven out of the previous nine years, the individual had to pay GBP ...Open official source ↗
- S24
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
This charge rose to GBP 60,000 for those non-domiciled individuals that had been resident in the United Kingdom for 12 out of the past 14 years. Open official source ↗
- S25
§ United Kingdom - Individual - Other taxes✓ verified 2026-07-16
Once an individual had been resident in the United Kingdom for 15 out of the previous 20 tax years, they became deemed UK domiciled and the remittance...Open official source ↗
- S26
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
The following types of personal income are exempt from tax in Cyprus: As of 16 July 2015, individuals who are not domiciled in Cyprus for SDC purposes...Open official source ↗
- S27
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
Thus, dividend and (most types of) interest income for such individuals are exempt from all taxes in Cyprus. Open official source ↗
- S28
§ Cyprus - Individual - Taxes on personal income✓ verified 2026-07-16
An individual who does not have ... for SDC purposes when the individual has been a tax resident of Cyprus for a period of at least 17 years out of th...Open official source ↗
- S29
§ Cyprus - Individual - Taxes on personal income✓ verified 2026-07-16
For dividend (SDC rate of 17% for profits of tax years up to 2025, including certain grandfathering provisions or 5% for profits of tax years as from ...Open official source ↗
- S30
§ Cyprus - Individual - Other taxes - Worldwide Tax Summaries✓ verified 2026-07-16
CGT applies only to gains relating to Cyprus-situated immovable property when the disposal is not subject to income tax. Open official source ↗
- S31
§ Cyprus - Individual - Other taxes - Worldwide Tax Summaries✓ verified 2026-07-16
Shares listed on any recognised stock exchange are excluded from CGT. Open official source ↗
- S32
§ Cyprus - Individual - Taxes on personal income✓ verified 2026-07-16
However, on 13 September 2023, the Cypress Tax Authority (CTA) issued a Circular pursuant of which rental income from self-catering accommodation that...Open official source ↗
- S33
§ Cyprus - Individual - Other taxes - Worldwide Tax Summaries✓ verified 2026-07-16
GHS contributions are capped at EUR 180,000 annual income. Open official source ↗
- S34
§ CG38550 - Temporary non-residence - the problem - TCGA92/S86 - HMRC internal manual - GOV.UK✓ verified 2026-07-16
TCGA92/S10A* prevents a taxpayer avoiding Capital Gains Tax by leaving the UK, disposing of assets while they are non-resident and then returning to t...Open official source ↗
- S35
§ CG38550 - Temporary non-residence - the problem - TCGA92/S86 - HMRC internal manual - GOV.UK✓ verified 2026-07-16
It applies if a UK resident taxpayer leaves the UK for a period of up to five complete ...Open official source ↗
- S36
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
Generally, the rules will apply where an individual meets the following conditions: They had ‘sole UK residence’ for either the whole or a part of at ...Open official source ↗
- S37
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
They had a ‘residence period’ that was not ‘sole UK residence’ in between 2 periods of ‘sole UK residence’. Open official source ↗
- S38
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
The total of the ‘residence periods’ that were not ‘sole UK residence’ did not exceed 5 years in length. Open official source ↗
- S39
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
If an individual whose year of return to the UK is 2024 to 2025 meets the conditions for temporary non-residence outlined above, then certain gains an...Open official source ↗
- S40
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
Such gains will therefore be taxed, with losses also becoming allowable, in 2024 to 2025. Open official source ↗
- S41
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
For these rules, the temporary period of non-residence may start or end within a tax year due to the ‘split year’ treatment (see section 5 of manual R...Open official source ↗
- S42
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
So, an individual who ceased to be UK resident in 2018 to 2019 or earlier and does not become UK resident again until 2024 to 2025 will not be within ...Open official source ↗
- S43
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
Subject to this, an individual who left the UK to live abroad and ceased to be resident in the UK will not be chargeable on gains made in years of ass...Open official source ↗
- S44
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
As of 1 January 2022, a new 50% exemption on remuneration applies for 'first employment' exercised in Cyprus by individuals who were not resident in C...Open official source ↗
- S45
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
The employment should commence after 1 January 2022, and the remuneration should exceed EUR 55,000 per annum. Open official source ↗
- S46
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
For each individual, the exemption will apply once in their lifetime for a period of 17 years. Open official source ↗
- S47
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
As of 26 July 2022, a new 20% exemption on remuneration (up to a maximum amount of exemption of EUR 8,550 per annum) applies for first employments com...Open official source ↗
- S48
§ Cyprus - Individual - Income determination✓ verified 2026-07-16
For each individual, the exemption will apply for a period of seven years, starting from the tax year following the tax year of commencement of employ...Open official source ↗
- S49
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ verified 2026-07-16
Signed on 22 March 2018. Open official source ↗
- S50
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ verified 2026-07-16
This Convention entered into force on 18 July 2018. Open official source ↗
- S51
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ verified 2026-07-16
... (ii) For income tax and capital gains tax for any year of assessment beginning on or after 6th April 2019; and · (iii) For corporation tax any fin...Open official source ↗
- S52
§ Cyprus: tax treaties - GOV.UK✓ verified 2026-07-16
... An amending protocol to the UK and Cyprus Double Taxation Convention was signed on 19 December 2018 in Nicosia. Open official source ↗
- S53
§ Cyprus: tax treaties - GOV.UK✓ verified 2026-07-16
This entered into force on 2 October 2019 and is effective in both countries from 1 January 2019. Open official source ↗
- S54
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ verified 2026-07-16
Notwithstanding the other provisions of this Convention, a benefit under this Convention shall not be granted in respect of an item of income or a cap...Open official source ↗
- S55
§ 2018 UK-Cyprus Double Taxation Convention as amended by the 2018 Protocol — in force - GOV.UK✓ verified 2026-07-16
This Convention shall apply to taxes on income and on capital gains imposed on behalf of a Contracting State or of its political subdivisions or local...Open official source ↗
- S56
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ verified 2026-07-16
Where a benefit under this Convention is denied to a person under paragraph 1, th b) where dividends are paid out of income (including gains) derived...Open official source ↗
- S57
§ HS278 Temporary non-residents and Capital Gains Tax (2025) - GOV.UK✓ verified 2026-07-16
The SRT rules also provide that a tax year may be split into a UK part and an overseas part. Open official source ↗
Material figures retain the cited passage used for verification. Excluded items never enter the main analysis.
What did not survive verification
Six figures did not survive verification. They are listed here, unpublished in the sections above. A figure enters this list when its source passage could not be re-confirmed at generation time.
- Q01confirm with your advisor
Residence Rules and Day Counts United Kingdom (Statutory Residence Test, in force since 6 April 2013):
No attached cited passage - Q02confirm with your advisor
The SRT came into effect on 6 April 2013.
The cited quote did not support the figure§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ verified 2026-07-16
This publication is available at https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-te...Open official source ↗
- Q03confirm with your advisor
Exceptional circumstances discount: capped at 60 days —
No attached cited passage - Q04confirm with your advisor
As of 2017, an individual is a tax resident of Cyprus if one satisfies either the '183-day rule' or the '60-day rule' for the tax year.
The cited quote did not support the figure§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ verified 2026-07-16
The '60-day rule' for Cyprus tax residency is satisfied for individuals who, cumulatively, in the relevant tax year: do not reside in any ot...Open official source ↗
- Q05confirm with your advisor
This makes the 5-year minimum absence the single most important planning threshold for the exit-tax risk. Confirm with your advisor the exact departure/return tax years to fix the S10A window precisely, and whether any shares should be disposed of before departure vs. after to avoid being caught if return to the UK is contemplated within 5 years.
No attached cited passage - Q06confirm with your advisor
Dividend article notes a special 15% cap only for certain property income vehicles:
No attached cited passage
Reviewer block.
This public sample has not been countersigned. A named professional countersignature for flagship briefs is in preparation.
This brief is machine-generated orientation material, prepared for review with a qualified tax advisor. The verification methodology is enforced in code at generation time and published at taxotax.com/how-we-verify.