塞浦路斯60天规则2026：现已允许双重税务居留, 英国FIG、阿联酋与瑞士叠加方案详解

塞浦路斯税法的一项重大修正案自2026年1月1日起生效，几乎未被主要的投资移民咨询公司注意到, 这一先发优势差距为与Mirabello Consultancy合作的投资者提供了实质性机会。

自2026年1月1日起，塞浦路斯已从其60天税务居民规则中删除了排他性居留条件。您不再需要在世界其他地方都是非居民，即可以每年仅60天实际居留获得塞浦路斯税务居民资格。 如果您持有阿联酋黄金签证、英国境外收入和收益（FIG）身份或瑞士包税制居留，您现在可以同时将塞浦路斯确立为第二税务居民地。

Mirabello Consultancy已为250多个投资移民案例提供咨询，批准率为99%。我们的IMC认证顾问驻扎于苏黎世、迪拜和香港。预约免费咨询，了解此次变化对您特定居留结构的意义。

Competitors including an industry source and an industry source continue to cite the pre-January 2026 rule on their websites as of this writing. Both still state the “no other 税务居民身份” condition as a requirement for the 60-day rule. This guide sets the record straight with A类认证核实 information from the January 2026 amendment.

什么是塞浦路斯60天税务居民规则？

塞浦路斯60天规则允许非欧盟投资者仅以每年60天实际居留建立塞浦路斯税务居民身份, 远低于大多数国家使用的标准183天门槛。 要获得资格，您必须在塞浦路斯维持永久住所，并在塞浦路斯税务居民实体中担任活跃的商业、雇佣或公司董事职务。

Established under Article 2 of the Cyprus Income Tax Law, the 60-day rule has positioned Cyprus as one of the most time-efficient EU 税务居民身份 options for internationally mobile investors and entrepreneurs. 该规则旨在吸引无法在单一司法管辖区承诺六个月年度实际居留的高净值人士。

The programme works in parallel with the Cyprus Permanent Residency by Investment programme (minimum €300,000): the residency permit establishes your legal right to reside in Cyprus indefinitely; the 60-day rule determines whether Cyprus becomes your tax residence in a given calendar year. Most Mirabello clients pursue both together.

2026年1月1日发生了什么变化, 为什么重要？

Effective 1 January 2026, Cyprus amended its Income Tax Law to remove the condition that 60-day rule applicants must not be tax resident in any other country. Investors who already hold UAE, Swiss, or UK 税务居民身份 can now simultaneously qualify for Cyprus 税务居民身份 with just 60 days of presence 每年. This is the most significant expansion of the 60-day rule since its introduction.

Before the 2026 amendment, the four conditions for qualifying as a Cyprus tax resident under the 60-day rule were:

1. Maintain a permanent home in Cyprus (owned or rented)
2. Carry on business, be employed, or hold a directorship in a Cyprus tax-resident company
3. NOT be tax resident in any other country, this condition was removed on 1 January 2026
4. Not spend 183 or more days in any single other country in the same year

The removal of condition 3 is the key change. Previously, holding UAE 税务居民身份 or UK FIG status would disqualify you from Cyprus 60-day status unless you relinquished the other residency first. That pre-condition is now gone from the statute.

The updated conditions from 1 January 2026 are:

• Minimum 60 days 实际居留 in Cyprus per calendar year
• Permanent home in Cyprus (owned or rented) maintained throughout the year
• Active business, employment, or directorship in a Cyprus tax-resident company
• Not more than 183 days in any single other country in the same year

As of early July 2026, neither an industry source nor an industry source has updated their Cyprus 60-day rule guidance to reflect this change. Investors relying on those guides are making residency decisions based on outdated information. Mirabello’s advisers work from verified, current sources.

谁从2026年双重居留修正案中获益最多？

The January 2026 amendment benefits three investor profiles: UAE Golden Visa holders wanting EU 税务居民身份 without surrendering UAE status; UK Foreign Income and Gains (FIG) holders seeking a second EU base during their 4-year FIG window; and Swiss Pauschalbesteuerung holders looking to add an EU residency alongside their lump-sum tax arrangement.

Profile 1, UAE Golden Visa holder: You reside primarily in the UAE, hold a UAE Golden Visa, and the UAE recognises you as a tax resident. The UAE imposes no personal income tax, so maintaining UAE 税务居民身份 carries zero tax cost. Before January 2026, establishing Cyprus 60-day 税务居民身份 required surrendering UAE 税务居民身份. Now, you can maintain both, spending 60 days in Cyprus annually while continuing to reside primarily in the UAE. Explore the UAE Golden Visa programme if you do not yet hold one.

Profile 2, UK FIG regime holder: The UK’s Foreign Income and Gains regime (which replaced the non-domiciled status in April 2025) gives qualifying individuals a 4-year exemption from UK tax on eligible foreign income and gains. UK FIG holders with significant international investment portfolios can now add Cyprus as a 税务居民身份 to access Cyprus non-dom benefits on their investment income, without needing to give up UK tax resident status. The regimes are independent; individual tax advice from a dual-jurisdiction specialist is essential.

Profile 3, Swiss Pauschalbesteuerung holder: Switzerland’s lump-sum taxation regime applies to foreign nationals residing in Switzerland who do not carry out gainful activity there. Swiss Pauschalbesteuerung holders can now additionally establish Cyprus 税务居民身份, gaining access to Cyprus’s 17-year non-dom exemption on dividends and interest income. The Swiss-Cyprus combination creates a legitimate two-country structure for investors with substantial international investment portfolios.

塞浦路斯60天居留如何与阿联酋黄金签证配合使用？

UAE Golden Visa holders can establish Cyprus 税务居民身份 under the updated 60-day rule without affecting their UAE Golden Visa or UAE tax resident status. The UAE imposes no personal income tax, so dual 税务居民身份 with Cyprus costs nothing in UAE tax terms. Cyprus non-dom status then exempts dividends (SDC 17%) and interest income (SDC 30%) for 17 years on income structured through Cyprus.

A UAE Golden Visa holder pursuing a UAE-Cyprus dual-residency structure would typically:

1. Acquire qualifying Cyprus property, minimum €300,000 in new-build residential property in Limassol or Paphos (most common route)
2. Establish an active Cyprus nexus, typically a directorship in a Cyprus-registered holding company, a standard structure for internationally mobile HNW investors
3. Spend 60 days 每年 in Cyprus, achievable through business visits, family stays, or property oversight visits
4. Apply for Cyprus Permanent Residency by Investment, government approval in 4-6 months
5. Register as a Cyprus tax resident with the Cyprus Tax Department once 60 days of annual presence are met, and claim non-dom status

The result is a UAE Golden Visa maintained, Cyprus EU 永久居留 established, and Cyprus non-dom status active. The UAE provides a zero-income-tax base for operating income; Cyprus provides an EU-member non-dom shield for dividends and investment returns.

One important limitation: Cyprus is an EU member state but is not yet a member of the Schengen Area. A Cyprus permanent residence permit allows you to live and work in Cyprus but does not grant automatic Schengen-zone travel rights. Investors wanting both EU residency and Schengen access should consider whether a Greece Golden Visa (from €400,000 in most zones) or a Malta Permanent Residency better meets their travel needs alongside Cyprus.

英国FIG制度如何与塞浦路斯非定居身份互动？

UK FIG (Foreign Income and Gains) holders who qualify as Cyprus tax residents under the 2026 60-day rule can access Cyprus non-dom status independently of their UK FIG entitlement. Cyprus non-dom exempts dividends (SDC 17%) and interest income (SDC 30%) for 17 years. The UK-Cyprus Double Taxation Agreement (DTA) governs which country has primary taxing rights over each income stream. Individual advice from a dual-jurisdiction tax specialist is required before structuring.

The UK FIG regime, introduced as the replacement for the UK non-domiciled status from April 2025, gives qualifying new UK residents a 4-year window during which they are exempt from UK income tax and capital gains tax on eligible foreign income. Investors who also establish Cyprus 税务居民身份 during this window can potentially access Cyprus non-dom exemptions at the Cyprus tax layer on investment income structured through Cyprus.

Key structural points on the UK-Cyprus interaction:

• UK tax residence is determined by the UK Statutory Residence Test (SRT), independently of whether you hold Cyprus 税务居民身份
• Cyprus tax residence under the 60-day rule is now available regardless of UK tax resident status since 1 January 2026
• UK-Cyprus DTA: the Double Taxation Agreement prevents double taxation but allocates taxing rights per income type, the agreement must be reviewed against your specific income profile
• Individual advice required: the FIG-Cyprus non-dom interaction involves two tax systems and a treaty; a qualified tax adviser experienced in UK and Cyprus law must confirm the appropriate structure

Mirabello Consultancy provides 投资移民 advisory services, not tax advice. Where the interaction between two tax systems is material to your decision, we connect clients with specialist tax counsel in both jurisdictions. Contact our team to discuss your situation.

瑞士包税制持有者能否获得塞浦路斯税务居民资格？

Yes. Swiss Pauschalbesteuerung holders can establish Cyprus 税务居民身份 under the updated 60-day rule since 1 January 2026. The former exclusive-residency condition that blocked this combination was removed by the January 2026 amendment. A Swiss lump-sum tax payer who spends 60 days in Cyprus, maintains a Cyprus property, and holds an active Cyprus directorship now qualifies as a Cyprus tax resident simultaneously with their Swiss Pauschalbesteuerung status.

Switzerland’s Pauschalbesteuerung applies to foreign nationals residing in Switzerland who do not carry out gainful activity in the country. Tax liability is assessed on a negotiated basis using the taxpayer’s annual living costs, a regime widely used by internationally mobile HNW investors who have chosen Switzerland as their European base of operations.

For Pauschalbesteuerung holders, adding Cyprus 税务居民身份 provides:

• Cyprus non-dom exemption on dividends and interest income at the SDC layer (17 years)
• An EU permanent residence permit as a complementary legal status alongside Swiss residency
• Cyprus’s English-language common-law legal system and EU-standard banking access
• A pathway to EU citizenship after 8 years of legal Cyprus residency (requires basic Greek A2)

The Switzerland-Cyprus combination can be structured as a legitimate two-country arrangement backed by the Switzerland-Cyprus Double Taxation Convention. As with all multi-jurisdictional residency structures, individual tax advice is essential.

Explore all EU and global residency options at Mirabello’s Golden Visa & Residency hub.

2026年塞浦路斯60天税务居民的申请条件是什么？

From 1 January 2026, to qualify for Cyprus 税务居民身份 under the 60-day rule you must: spend at least 60 days in Cyprus in the calendar year; maintain a permanent home in Cyprus (owned or rented); hold business activities, employment, or a directorship in a Cyprus-registered company; and not spend 183 or more days in any single other country in the same year. Dual 税务居民身份 elsewhere is now permitted.

Condition	Requirement (2026)
Physical presence	Minimum 60 days in Cyprus per calendar year
Permanent home	Own or rent accommodation in Cyprus, maintained throughout the year
Business nexus	Active business, employment, or directorship in a Cyprus tax-resident company
Other-country cap	No more than 183 days in any single other country in the same year
Dual 税务居民身份	Permitted from 1 January 2026, exclusive-residency condition removed

Most Mirabello clients pursuing the Cyprus 60-day route also apply for Cyprus Permanent Residency by Investment simultaneously. The PR programme (minimum €300,000 investment, €50,000 annual foreign income) establishes your legal right to reside in Cyprus indefinitely; 税务居民身份 registration follows once 60 days of presence are achieved in the relevant calendar year.

2026年塞浦路斯永久居留需要什么投资？

Cyprus Permanent Residency by Investment requires a minimum €300,000 investment in new-build residential property, commercial property, company shares, or a qualifying Cypriot investment fund. The income requirement is €50,000 每年 from foreign sources, plus €15,000 per dependent spouse and €10,000 per dependent child. Government fees are approximately €570 per main applicant. Total first-year costs including property and all fees typically range from €330,000 to €365,000.

The four qualifying investment routes:

• New residential property (most popular): minimum €300,000 in new-build property purchased from a developer, resale properties do not qualify. Limassol and Paphos dominate the investor market. Reduced 5% VAT available on the first 200 sqm for first-time residential purchasers.
• Commercial property: minimum €300,000 in offices, hotels, shops, or other commercial units in Cyprus
• Cyprus company shares: minimum €300,000 in a Cyprus-registered company employing at least 5 staff in Cyprus
• Collective investment fund: minimum €300,000 in a qualifying Cyprus Investment Funds Association (CIFA) fund

Additional transaction costs to budget for when purchasing residential property:

• Stamp duty: 0.15% on the first €170,860, then 0.2% on the excess
• Land Registry transfer fees: 3-8% of property value (scaled by value)
• Legal fees: typically €3,000-€6,000
• Private health insurance: approximately €170+ per person 每年 (mandatory for PR applicants)
• Government application fee: €500 per application + €70 per person for the residence card

塞浦路斯为税务居民提供哪些税务优惠？

Cyprus tax residents who qualify for non-dom status pay zero Special Defence Contribution (SDC) on dividends, interest income, and certain rental income for 17 years from the date of becoming tax resident. There is no wealth tax, no inheritance tax, and no annual property tax in Cyprus. Corporate tax is 15% from January 2026. Non-dom status is automatic, no application is required.

Tax Type	Standard Rate	Non-Dom Rate (17 yrs)
Personal income (first €19,500)	0%	0%
Dividends (SDC)	17%	0%
Interest income (SDC)	30%	0%
Rental income (SDC component)	3%	0%
Capital gains, Cyprus property	20%	20%
Capital gains, securities/shares	0%	0%
Wealth tax	None	None
Inheritance tax	None	None
Corporate tax	15% (Jan 2026)	15%

The 17-year non-dom window is one of the most extended in Europe. Non-dom status is automatic once you register as a Cyprus tax resident and confirm your non-domicile status with the Cyprus Tax Department, no separate application or annual renewal is required.

Under the 2026 Cyprus tax reform, a continuation option is now available after the 17-year period: two consecutive 5-year extensions are available subject to a lump-sum payment per period, preserving long-term attractiveness for investors who remain in Cyprus beyond the initial window.

Sources: PWC Cyprus Tax Summaries 2026 | Cyprus Civil Registry and Migration Department (official)

建立塞浦路斯税务居民身份需要多长时间？

Cyprus Permanent Residency by Investment is processed in 4-6 months, one of the fastest EU 居留项目s available. The end-to-end process involves property acquisition (2-8 weeks), documentation preparation (2-4 weeks), government due diligence (8-16 weeks), and residence card issuance (2-4 weeks). Tax residency under the 60-day rule is established once you have spent 60 days in Cyprus within the relevant calendar year and registered with the Cyprus Tax Department.

The full timeline step-by-step:

1. Initial consultation and property search (2-6 weeks), Mirabello advisers identify qualifying properties in Limassol or Paphos based on your investment profile and timeline
2. Property acquisition (2-4 weeks after selection), purchase agreement, deposit, completion, and title deed process initiated
3. Documentation preparation (2-4 weeks), apostilled criminal record certificates, proof of €50,000+ annual foreign income, private health insurance, certified marriage and birth certificates as applicable
4. Application submission to the Civil Registry and Migration Department
5. Government due diligence and approval by the Ministry of Interior (8-16 weeks)
6. Biometrics collection and residence card issuance (2-4 weeks after approval)
7. Tax residency registration with the Cyprus Tax Department once 60 days of presence are accumulated in the calendar year

Cyprus’s 4-6 month 处理时间 compares favourably with the Greece Golden Visa (3-9 months, €400,000+ in most zones). To maintain Cyprus 永久居留, you must visit Cyprus at least once every 2 years, one of the lowest ongoing presence requirements in Europe.

To compare Cyprus against Greece, UAE Golden Visa, and other leading European residency options, explore the Mirabello Programme Comparison Grid or the Mirabello Investment Migration Index, updated quarterly to reflect programme changes.

关于塞浦路斯60天税务居民和双重居留的常见问题（2026年）

塞浦路斯60天税务居民现在与阿联酋黄金签证持有者兼容吗？

Yes. Since 1 January 2026, Cyprus removed the exclusive-residency condition from the 60-day rule, making it compatible with UAE Golden Visa status. UAE Golden Visa holders can spend 60 days in Cyprus 每年, maintain a Cyprus property and directorship, and qualify as Cyprus tax residents, while retaining their UAE Golden Visa and UAE 税务居民身份. The UAE imposes no personal income tax, so no UAE tax cost is incurred by adding Cyprus as a second 税务居民身份.

2026年1月的变化是否影响寻求塞浦路斯居留的英国FIG制度持有者？

Yes. Prior to January 2026, UK tax residents could not qualify for Cyprus 税务居民身份 under the 60-day rule without relinquishing UK residency. The January 2026 amendment removes that barrier. UK FIG (Foreign Income and Gains regime) holders who meet the Cyprus conditions, 60 days, permanent home, active Cyprus directorship, and no single other country for 183+ days, can now establish Cyprus 税务居民身份 simultaneously. The interaction with the UK Statutory Residence Test and the UK-Cyprus Double Taxation Agreement requires individual tax advice before structuring.

什么是塞浦路斯非定居身份，谁自动获得资格？

Cyprus non-dom (non-domiciled) status exempts individuals not domiciled in Cyprus from Special Defence Contribution (SDC) on dividends (17%), interest income (30%), and certain rental income for 17 years from becoming a Cyprus tax resident. Non-dom status is automatic for all new Cyprus tax residents who are not domiciled in Cyprus, the vast majority of international investors qualify. No separate application or annual renewal is required; it takes effect upon registering as a Cyprus tax resident and confirming non-domicile status with the Tax Department.

塞浦路斯永久居留许可证是否授予申根区旅行权？

No. Cyprus is an EU member state but is not yet a member of the Schengen Area. A Cyprus Permanent Residency permit allows you to live and work in Cyprus indefinitely but does not grant automatic Schengen-zone travel rights. Investors wanting both EU residency and Schengen access should consider combining Cyprus with a Greece Golden Visa (Schengen + EU, €400,000 entry in most zones) or a Malta Permanent Residency (Schengen + EU, from €300,000).

如何开始与Mirabello Consultancy合作？

Mirabello Consultancy has advised on over 250 citizenship and residency by investment cases with a 99% approval rate. We are IMC-certified and ACAMS-certified, based in Zurich, Dubai, and Hong Kong. To explore the Cyprus 60-day 税务居民身份 rule or the Cyprus Permanent Residency by Investment programme, book a free consultation with our team. We will assess your existing residency structure, income profile, and international mobility goals, and recommend the most suitable multi-residency strategy for your situation. We can typically accommodate initial consultations within 48 hours.