In summary…
Cyprus recognizes you as a tax resident through two channels: more than 183 days within the year, or at least 60 days combined with on-site work, accommodation in Cyprus, and no more than 183 days in another country. The concept of "non-dom" (non-resident) is not a matter of personal preference: it refers to the absence of a Cypriot domicile, which is presumed once you have been a tax resident. 17 of the last 20 years. The exact impact this status has on your income is confirmed by the Cypriot tax authorities.
But becoming a resident of Cyprus does not mean you leave France. If your home remains in France, the French administration can consider you domiciled there, regardless of the number of days spent in Limassol. It is the break on the French side, and not the Cypriot certificate, that decides.
«"I signed a lease in Limassol and created my local company, so I am Cypriot for tax purposes?" We hear this from Lyon executives who are preparing to leave, and the answer is in two parts: yes maybe for Cyprus, no not yet for France.
1. Cyprus: two entry points, only one is enough
The single door: over 183 days
A person is considered a Cypriot tax resident if they stay in Cyprus for more than 183 days in total during the tax year, whether for one period or several. There are no requirements regarding employment or residence. The day of arrival counts as a day spent in Cyprus, and the day of departure as a day spent abroad.
The narrow gate: 60 days, but four cumulative conditions
For those who travel frequently, Cypriot law provides a second option. According to the text of the law, this option only applies if all four conditions are met in the same year:
- No more than 183 days in another country over the year, by adding up the periods spent in that country.
- At least 60 days in Cyprus within the year.
- An activity in Cyprus : carrying on a business, employment, or a position (e.g., manager) within a person who is themselves a Cypriot tax resident. The condition is not met if this activity, employment, or position ends within the year.
- Permanent accommodation in Cyprus, owned or rented by you.
Specifically. One single omission and the door closes: a lease without employment or a local mandate, a contract ending in November, 190 days spent in a third country. The required documentation includes: a dated contract or mandate, the lease agreement, and a detailed breakdown of the days spent in a third country supported by travel documents. The practice of the Cypriot Tax Department (the tax authorities) is confirmed with him before relying solely on these conditions.
For the technician. Income Tax Act 2002 (Act No. 118(I)/2002), Article 2, definition of "resident of the Republic": the first case applies to those residing for more than 183 days, the second to those residing for 60 days, with cumulative conditions and a reservation regarding cessation of activity during the year. Text accessed on 23/10/2026 on the Cypriot legal database CyLaw (non-governmental copy of the text).
2. Non-dom status: the absence of a home, not a favor being requested
What creates it, what extinguishes it
The concept of "non-dom" (non-domiciled) stems from the distinction Cypriot law makes between tax residence and domicile. A French citizen who moves to Cyprus has an original domicile elsewhere: they are a Cypriot tax resident, but not "domiciled" in Cyprus.
Cypriot domicile is presumed when you have been a Cypriot tax resident for at least 17 of the last 20 years. Before this threshold, the status is maintained without any action required.
For the technician. Law No. 245(I)/2025 amending Law No. 117(I)/2002 on the Special Contribution for the Defence of the Republic (published in the Official Journal of Cyprus on 31 December 2025): Article 2, paragraph 3 (presumed domicile after 17 years of tax residence in the last 20 years); flat-rate option for deemed domiciled residents. Text read on CyLaw, non-governmental copy.
What the status does not address
It says nothing about residency on the French side. And what exactly it changes for your Cypriot income (salaries, dividends, interest) must be confirmed with the Cypriot tax authorities before any decision is made: the special defence contribution, a Cypriot tax based in particular on dividends and interest, was modified by Law No. 245(I)/2025, and we do not specify its rates or their date of application, due to a lack of official confirmation.
3. On the French side: one outbreak remaining here cancels out the rest
Three criteria, only one is enough
French law doesn't just count the days. You remain a tax resident of France if mon The three criteria of Article 4 B of the French General Tax Code (CGI, the compilation of French tax laws) are met: your home, or failing that, your principal residence, is in France; you carry out a professional activity there, unless it is secondary; and the center of your economic interests is located there. The figure of 183 days, often cited for principal residence, is a matter of legal doctrine and is not a threshold set by Article 4 B.
This is the classic trap of leaving for Cyprus: you carefully count the days and leave your family, house, or productive assets in France. The details of the three criteria are in the article devoted to article 4 B.
When both countries demand it of you: the convention
If you are a resident of both countries, the tax treaty between France and Cyprus will determine which applies. The current treaty dates from December 18, 1981, and has been in effect since January 1.st April 1983. A taxpayer resident in both States is attached, in this order, to the State of his permanent home, then to the State of his center of vital interests (closest personal and economic ties), then to his habitual residence, then to his nationality; failing that, the two administrations agree.
A new convention was signed in Nicosia on December 11, 2023. It was adopted by the Senate on February 19, 2026; the report of the National Assembly's Foreign Affairs Committee was submitted on June 3, 2026. As of October 23, 2026, the National Assembly's file indicates neither final adoption nor promulgation: the 1981 convention therefore remains applicable.
For the technician. Franco-Cypriot Convention of 18 December 1981, Article 4 (residence of natural persons and tie-breaker criteria), consolidated version with the multilateral instrument published on impots.gouv.fr, which does not replace the official texts. 2023 Convention: Bill No. 314 (Senate), No. 2516 (National Assembly).
Case study: 75 days in Cyprus, a family in Lyon
Situation. A Lyon-based executive employed by a Cypriot company has a lease in Limassol. His wife and two children remain in Lyon, in the family apartment; the Limassol lease also provides him with a permanent residence in Cyprus. The year's schedule is as follows: 75 days in Cyprus, 128 days in France, and 162 days abroad in other countries, including 90 days in any one third country (75 + 128 + 162 = 365).
Issue. On the Cypriot side, the 183-day test is not met (75 days), but the 60-day test is met: 75 ≥ 60, no other country beyond 183 days, employment in Cyprus, rented accommodation. On the French side, 128 days falls short of the 183 days required by law for principal residence, but the residence in Lyon alone is sufficient under Article 4 B. Resident of both countries.
Strategy. The counting of days is not the lever: the family settles in Cyprus, the Lyon apartment is sold or rented without family use, and it remains to control professional activity and the center of economic interests.
Result. Before: 75 days out of 365, or 20.5% of the year, in Cyprus, a dual residence, and, according to the tie-breaker order of the 1981 convention (permanent home in both States, then center of vital interests), classification in France since the center of vital interests is in Lyon. After: the home is no longer in France, the home criterion disappears, and the other two criteria must be verified individually. Illustrative example, calculated using the rules in force on 23/10/2026.
Our position
Order the departure: the home first, then the days
A move to Cyprus is planned in this order: relocate the household, declare the new address to the non-resident tax office, and review the...’exit tax (French tax on unrealized capital gains from securities upon departure; it requires at least six years of tax residence in France out of the last ten and securities worth at least €800,000, or representing at least 50% of a company's profits), then document the days. For the rest: leaving France for Cyprus, declare your address abroad and the exit tax.
Related questions
Is it possible to be a Cypriot tax resident without spending 183 days there? Yes, through the 60-day rule, which, according to the law, requires four cumulative conditions: no more than 183 days in another country, at least 60 days in Cyprus, employment in Cyprus, and permanent accommodation owned or rented. If the employment ends within the year, the condition is not met.
How long does non-dom status last? Until you have been a Cypriot tax resident for at least 17 of the last 20 years, Cypriot residence is presumed. The impact of this status on your income must be confirmed with the Cypriot tax authorities.
Is owning a property in Cyprus enough to escape French taxation? No. Only one of the three criteria in Article 4 B is sufficient to maintain tax residence in France, and the home is one of them. The treaty only makes a distinction if you are a resident of both countries, and it begins with the permanent home.
Are you planning a trip to Cyprus and your family isn't coming right away?
The initial consultation is used to assess the French and Cypriot criteria applicable to your situation and to establish the order of procedures. Forty-five minutes, with no obligation.
Are you a notary, chartered accountant, lawyer, or fellow consultant? And a client is leaving for Cyprus? We act as a co-contractor on the residence and proof: the client remains yours, we give you back the criteria grid and the schedule of procedures.
Book an appointment
The initial consultation is to establish your exact situation and determine if there is anything that can be done—sometimes there is nothing, and we will say so as well. Thirty minutes, with no obligation.
Book an exchange with Balmont Conseil
Alexis Sagnier, financial and real estate investment advisor, insurance broker, AMF certified. ORIAS 13003497. Updated on 23/10/2026.
Official sources consulted
- Service-public.gouv.fr, "How to determine your tax residence?": https://www.service-public.gouv.fr/particuliers/vosdroits/F62
- BOFiP, BOI-ENR-DMTG-10-10-30 (tax domicile, article 4 B of the CGI): https://bofip.impots.gouv.fr/export/pdf/6016
- Impots.gouv.fr, «Do I have to pay an exit tax? »: https://www.impots.gouv.fr/international-particulier/questions/i-am-leaving-france-do-i-have-pay-exit-tax
- Impots.gouv.fr, France-Cyprus tax treaty: https://impots.gouv.fr/portail/node/13653
- Senate, report no. 369 (2025-2026) on the France-Cyprus convention: https://www.senat.fr/rap/l25-369/l25-369_mono.html
- National Assembly, legislative file of the bill: https://www.assemblee-nationale.fr/dyn/17/dossiers/DLR5L17N53706
- Cypriot legislation: Law No. 118(I)/2002 (Income Tax) and Law No. 245(I)/2025 amending Law No. 117(I)/2002 (Special Defence Contribution), texts consulted on the Cypriot legal database CyLaw.
