Navigating the 60-Day Rule – A Strategic Relocation of a Tech Consultancy to Cyprus

Our client, a high-net-worth software architect based in Central Europe, operated a cross-border consultancy generating over €250,000 in annual profit. Facing rising local tax pressures and complex social security contributions, the client sought a legally compliant EU-based structure that would offer tax efficiency without requiring a full-year physical presence in a single country.

The Challenge

The primary challenge was “Tax Residency entrapment.” The client traveled frequently for business and leisure, making it difficult to satisfy the traditional 183-day rule in most jurisdictions. Furthermore, they required a solution that would be recognized by international banks to ensure seamless B2B transactions.

The Solution: The Cyprus 60-Day Rule & Non-Dom Status

TaxRelocate designed a transition plan centered on the Cyprus 60-Day Residency Rule (introduced as an amendment to the Income Tax Law).

  1. Corporate Restructuring: We assisted in incorporating a Cyprus Private Limited Company. This allowed the client to benefit from a 15% corporate tax rate (with potential further reductions via IP Box or Notional Interest Deduction).

  2. Personal Residency: By proving the client did not stay in any other single country for more than 183 days and maintaining a permanent residence in Cyprus (rented), we secured Cypriot Tax Residency under the 60-day provision.

  3. Non-Domicile Status: We successfully applied for the Non-Dom status, which grants a 17-year exemption from the Special Defence Contribution (SDC).

The Result

  • Tax Efficiency: The client’s effective tax rate on dividends dropped to 0%.

  • Social Security Optimization: By structuring a modest director’s salary, the client significantly reduced mandatory social contributions while maintaining full EU health insurance coverage (GESY).

  • Compliance: The client received a Tax Residency Certificate (TRC), providing a solid defense against potential “center of vital interests” inquiries from their former home country.

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