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Question Cypriot Non Dom looking for possibility to NOT spend 2 Month in Cyprus

cypriotnondom

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Hey there,

I have
My actual Situation is following:
German citizen with tax residence in Cyprus with Cypriot Ltd. and Non-Dom status in Cyprus. (since 2020)
I don't want to stay the 2 months in Cyprus anymore. (spending most time in different Asian Countries, Nowhere more then 180 days)
At the moment I receive a small salary from the Cypriot company + amounts of dividend payments.

I was running an e-commerce business through the Cyprus company. However, I sold it at the end of last year and at the moment I am not 100% sure if I will do e-commerce again. Maybe I will put the cypriot company to sleep for a bit.

My time split at the moment looks like this: 2 months in Cyprus, 2-3 weeks in Germany and the rest in Bali, Thailand and Colombia.
I would like to leave out the 2 months in Cyprus.
I thought about if it would be maybe possible with a Portugal NHR status?

From my research I would need:
-office space and 1 other director in cyprus
-1 Appartement for yearly rental in Portugal (could get rent from a friend there)

What other options would I have here? Is there something else to look into?
 
Every solution will "work" until Germany asks you for a tax certificate to prove that you are a tax resident elsewhere- regardless of Portugal, CY or Thailand or Mars. No country will give you such a certificate unless you actually spend the minimum required time there.

Cyprus is by far the easiest with only 60 days requirement.

If you can't do that, then you take the risk of Germany asking you in 5 years to prove you were actually not living in Germany or be taxed to death, and the German tax office is notorious for that. Don't be stupid, sit your 60 days and get your tax certificate.
 
Are there special reasons for this? You can't or you would rather not?
I don´t want to because I want to be flexible where I spend time.

Every solution will "work" until Germany asks you for a tax certificate to prove that you are a tax resident elsewhere- regardless of Portugal, CY or Thailand or Mars. No country will give you such a certificate unless you actually spend the minimum required time there.

Cyprus is by far the easiest with only 60 days requirement.

If you can't do that, then you take the risk of Germany asking you in 5 years to prove you were actually not living in Germany or be taxed to death, and the German tax office is notorious for that. Don't be stupid, sit your 60 days and get your tax certificate.
appreciate your feedback.
ok thanks I have to check again. Thought you get a tax certificate with the NHR Status. Definitely won´t spend more then 2-3 Weeks per year in Germany.
 
Don't be stupid, sit your 60 days and get your tax certificate.

I have same setup. However, I do spend more than 2 months in Cyprus (for now).

Do you recommend to ask for a tax certificate every year?
@CyprusLawyer101 : I will be interested about your opinion.

At first, I am thinking: I would request tax certificates from Cyprus only if my home country bothers me in few years.
But will it be possible and easy to get it retrospectively?

On the contrary, I guess I will be under more scrutiny from Cyprus every year. Which I do not mind so much because I have nothing to hide and full-fill non-dom conditions for now.
 
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I have same setup. However, I do spend more than 2 months in Cyprus (for now).

Do you recommend to ask for a tax certificate every year?
@CyprusLawyer101 : I will be interested about your opinion.

At first, I am thinking: I would request tax certificates from Cyprus only if my home country bothers me in few years.
But will it be possible and easy to get it retrospectively?

On the contrary, I guess I will be under more scrutiny from Cyprus every year. Which I do not mind so much because I have nothing to hide and full-fill non-dom conditions for now.

Where are you from friend ?
 
@cypriotnondom does the Malta GRP program be of some use here? IIRC, as long as you don't spend more than 183 days in any one country you will get a tax resident certificate in Malta
I asked one of the biggest law firms in Malta and they said it's not the case, it's 6 months and from there you can get it in less if you have ties (company, house, family in Malta etc)
 
Curious OP @cypriotnondom, what did you end up doing? I'm in a similar situation, debating if I should sit out my 60 days or take the risk. Leaning towards sitting this year. Looking at possibly going for the NHR as-well, but worried about the PE rules since my Cypriot LTD currently has no substance.

Also, would be happy if you wanted to PM me @CyprusLawyer101 and/or @CyprusLaw
 
Curious OP @cypriotnondom, what did you end up doing? I'm in a similar situation, debating if I should sit out my 60 days or take the risk. Leaning towards sitting this year. Looking at possibly going for the NHR as-well, but worried about the PE rules since my Cypriot LTD currently has no substance.

Also, would be happy if you wanted to PM me @CyprusLawyer101 and/or @CyprusLaw
Honest question: do you dislike Cyprus that much as to not want to spend 2 months there?

I'm thinking of moving there next year, to be honest Cyprus seems like the best deal to get a low effort tax residency: only two months residency in a sunny place with beaches. Only downside is that you need to have an appartment rented but you can structure it so it's low cost (Rent a low cost one or even try to split the rent with someone else). Haven't seen anything that good anywhere else to be honest so I'm genuienly curious if you dislike it that much.
 
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Curious OP @cypriotnondom, what did you end up doing? I'm in a similar situation, debating if I should sit out my 60 days or take the risk. Leaning towards sitting this year. Looking at possibly going for the NHR as-well, but worried about the PE rules since my Cypriot LTD currently has no substance.

Also, would be happy if you wanted to PM me @CyprusLawyer101 and/or @CyprusLaw
You need to stay 60 days in Cyprus to get their domestic tax certificate, which is in many cases, quite useless since if you become a tax resident anywhere else, it is immediately void.
The only thing you should probably worry about is getting a tax certificate based on the double tax treaty with the country of your citizenship or past tax residence where you perceive risks.
Check what the bilateral treaty says. Nowhere does it say anything about 60 days.
If you want to have some tax certificate for your peace of mind without triggering certain jurisdictions where you want to stay under the radar, you can also get it on the basis of a treaty with some 3rd country where you have 0 ties. You don't even necessarily need to deal with bureaucrats in Cyprus to obtain such a certificate.

If you maintain a home in Cyprus as your only permanent home and go on a trip around the world, you should be able to remain a Cypriot tax resident staying there 0 days per year.
 
Honest question: do you dislike Cyprus that much as to not want to spend 2 months there?
They've got some pretty chill rules over in Cyprus, like you only gotta be there for 2 months a year to qualify for their tax setup! If you can't swing that, I'd forget about trying to cut your tax bill through some overseas company and instead take a look at sorting it out locally.
 
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