The relocation wave of 2020–2023 spread across several European routes: Portuguese NHR, the Spanish digital nomad visa combined with the Beckham regime, French long-term residence permits. What these routes had in common was a special tax regime — or the expectation that the tax question could be dealt with later. Several years on, many clients are approaching the point where the original residency structure needs to be revisited: the preferential tax period is ending, an immigration status is coming up for renewal, or actual living patterns are beginning to create a full tax position. This article is about why Cyprus increasingly appears at that point, how the Cypriot non-dom status works, and what it requires in practice.
Three routes reach a point of revision
Portugal. The classic NHR regime has been closed to new applicants since 2024. Clients whose first NHR year was 2017–2019 are spending the final years of the regime in 2026–2028 and transition to ordinary taxation from 2027 to 2029 respectively. After exit, foreign investment income is analysed under Portugal's ordinary rules: dividends and interest are taxed at a base rate of 28%, subject to the rules of the specific income category and the option to aggregate the income with other taxable income where applicable; other categories fall under the progressive scale of up to 48% plus the solidarity surcharge. The IFICI regime that replaced NHR is tied to qualifying professional roles and is generally not available to a capital holder without active engagement in the approved sectors. We cover this mechanism in detail on our Portugal jurisdiction page and in the article on the Modelo 3 return.
Spain. The first cohort of Digital Nomad Visa holders is entering the renewal cycle — and at the same time, their actual tax position for the years since relocation is becoming clear. Holding or renewing a residence permit does not create tax residency automatically: residency is determined separately, under Spanish tax criteria. But where the client has in fact been living and working from Spain, the tax residency question can no longer be deferred by the time of renewal. A properly elected Beckham regime runs for a maximum of six tax years and does not cover everything; without it, an ordinary Spanish resident faces worldwide IRPF, wealth tax analysis and foreign asset reporting (Modelo 720) where the relevant conditions are met. For this group, «renew or relocate» has ceased to be a theoretical question.
France. For clients holding a French residence permit, the key question after several years is whether the declared immigration position matches the client's actual living arrangements and tax-residency position. French tax residency can lead to taxation of worldwide income and, where relevant real estate is held, to the French real estate wealth tax; automatic exchange of information gives the French tax authority visibility over foreign accounts and income. The specific presence and renewal requirements depend on the permit category. The French scenario therefore calls for a separate reconciliation of the immigration and tax history — rather than an assumption that holding the permit itself settles the residency question.
The common denominator: a construction that worked in the first years after relocation does not necessarily remain optimal later. The decision on the next tax residency is best taken before the preferential period ends — or before a conflict emerges between actual living patterns and the declared tax position.
Why Cyprus appears at this point
For a Russian HNWI, Cyprus today occupies a distinct place among EU jurisdictions. It combines a long non-dom regime for foreign passive income, tax residency through the 60-day test, and — critically since 2022 — a functioning immigration route that remains available to Russian citizens.
Comparable domicile- and remittance-based tax regimes exist elsewhere — Malta and Ireland, for example. But practical accessibility differs: Malta has suspended its investment programmes for Russian and Belarusian applicants, and Ireland closed its Immigrant Investor Programme to all new applicants in 2023. Cyprus, by contrast, retains an investment route to permanent residence status for third-country nationals, including Russian applicants — subject to sanctions, banking and documentary screening.
Non-dom: up to 17 years of preferential treatment for foreign passive income. For a Cypriot tax resident with non-dom status, dividends and interest are exempt from the SDC — the Special Defence Contribution, Cyprus's tax on passive income. On this component the Cypriot rate is effectively 0%; the GESY contribution applies separately. Gains on ordinary securities unconnected with Cypriot real estate are, as a rule, outside the scope of Cypriot capital gains tax — regardless of non-dom status. A person generally becomes deemed domiciled for SDC purposes once they have been a Cyprus tax resident for at least 17 of the preceding 20 tax years. The 2026 reform introduced the option, once the ordinary non-dom period is exhausted, to elect an alternative SDC treatment for a five-year period, subject to a fixed payment of €250,000 for that period.
It is important to state the mechanics honestly: Cyprus tax residents are generally subject to income tax on worldwide income, subject to the exemptions and special rules of the Cypriot tax system, and the filing obligation remains. From 2026 it has been broadened: for most Cypriot tax residents aged 25–70, the obligation to file an individual return arises regardless of the amount of income. Non-dom is a preferential treatment of specific income categories — not an exemption from tax reporting. The low effective burden on capital income is the product of a system of exemptions, not the absence of a tax system. The GESY healthcare contribution remains — 2.65% on the relevant passive income, subject to an annual contribution base cap of €180,000: the maximum annual contribution on such income is €4,770. For a large investment portfolio, once the GESY cap is reached, the effective burden on total passive income can fall to a fraction of one percent.
The 60-day test: tax residency without 183 days on the island. Cyprus allows an individual to become tax resident after spending at least 60 days in Cyprus during the calendar year — provided all the remaining conditions are met simultaneously: the individual does not spend more than 183 days in any other country, is not a tax resident of another state, maintains a permanent home in Cyprus (owned or rented), and carries on business in Cyprus, is employed in Cyprus, or holds an office in a company established in Cyprus. This is an unusually low physical-presence threshold by European standards. For someone leaving a jurisdiction where the question of actual residence has become painful, this is a structurally different position: residency is achievable without moving one's entire life to the island — but it must be real, as discussed below.
Permanent immigration status through investment. One route to the fast-track Cypriot Immigration Permit is the purchase of a new residential property from a developer for at least €300,000 plus VAT. Beyond the investment, the applicant must evidence a minimum annual income — €50,000 for the main applicant, with additional amounts for family members — and meet the programme's remaining requirements. The status confers a permanent right of residence in Cyprus. Acquiring a home can simultaneously address the immigration objective and satisfy the housing element of the 60-day tax test; the remaining conditions — physical presence, absence of tax residency elsewhere, and an economic connection with Cyprus — are evidenced separately. A genuinely available permanent home in Cyprus is also relevant to the analysis of dual tax residency under an applicable treaty — although property ownership does not of itself resolve such a conflict: where a permanent home is available in both states, the analysis may then move to the centre of vital interests and the remaining treaty tie-breaker criteria.
What is required in practice
The Cypriot construction does not operate automatically — each condition is factual and is examined.
Non-dom status must be formally documented. The SDC exemption arises from the law where the criteria are met; in practice, however, the status is documented through the relevant declaration and Tax Department confirmation. Banks and income payers may request this documentation in order to apply the exemption correctly. Completing it is part of the standard entry procedure, not an option.
Residency must be real. Sixty days is a minimum of presence, not a licence for «paper residency». Under the 60-day test, physical presence, a permanent home and the statutory economic connection with Cyprus — business activity, employment or an office in a Cypriot company — must all be satisfied at the same time. A Cypriot tax residency certificate does not displace the analysis on the other side: if the client in fact continues to live in another state, competing residency may arise, together with the need to apply the relevant double tax treaty. Reproducing in Cyprus the same approach that caused difficulties in the previous jurisdiction will create many of the same risks — except that the Cypriot threshold is materially easier to satisfy in practice.
The transition requires closing the previous position. A change of jurisdiction is not only the entry into Cyprus but also a correct exit: the final return in the previous country, properly documenting the end of the previous tax-residency position and — where local procedure provides for it — updating the status in the tax register, alignment of dates, and, where structures exist, a review of their configuration under Cypriot and Russian CFC rules. Exit mistakes may surface years later — in the form of an inquiry from a jurisdiction the client believed had already been closed.
How EMET handles the transition
EMET treats the transition not as obtaining a Cypriot residency certificate, but as a coordinated transition between two tax-residency positions: closing the previous one and establishing the Cypriot one. It is the gap between these two dates that most often generates subsequent questions from tax authorities and banks. The scope covers analysis of the position in the country of exit (including open obligations and visibility under automatic exchange of information), establishing the Cypriot tax-residency position — from the 60-day configuration and the property acquisition to formalising non-dom status and the first Cypriot return — coordination with banks on consistency of source of funds, and the Russian tax and CFC position where it remains relevant.