United Kingdom → Cyprus
Advisor-ready analysis with live-fetched, claim-level evidence and a sequenced execution plan.
The verified findings at a glance.
An individual will be UK resident if they spend 183 days or more in the UK in the relevant tax year (the first automatic UK test under the Statutory Residence Test).
→ Key findingsAn individual will be non-UK resident for a tax year if they were UK resident in one or more of the prior 3 tax years and spend fewer than 16 days in the UK; or if they were not UK resident in any of the prior 3 tax years and spend fewer than 46 days in the UK.
→ Key findingsAn individual working full-time overseas can be non-UK resident if they spend fewer than 91 days in the UK in the tax year, work more than 3 hours in the UK on fewer than 31 days, and have no significant break from overseas work.
→ Key findingsAn individual has a 90-day tie for the tax year if they spent more than 90 days in the UK in either or both of the previous 2 tax years.
→ Key findingsThe deeming rule applies where an individual has been UK resident in one or more of the 3 previous tax years, has at least 3 UK ties, and has been present in the UK on more than 30 days without being present at the end of the day (a qualifying day) in the tax year.
→ Key findingsThe UK and Cyprus Double Taxation Convention governs the allocation of taxing rights over income and capital gains between the two states and has been in force since 2018, with an amending protocol effective from 2019.
→ Treaty analysisConfirm whether the software company stake is held directly or via a holding structure, and verify the 2-year employee/office-holder and trading-company conditions required to qualify for Business Asset Disposal Relief ahead of the planned 2026 sale.
→ Execution plan
The decision in figures.
Top personal income-tax rate
Capital-gains rate
Wealth tax
Inheritance tax
Exit tax
Claims with their evidence.
An individual will be UK resident if they spend 183 days or more in the UK in the relevant tax year (the first automatic UK test under the Statutory Residence Test).
§ RFIG20320 - Statutory Residence Test (SRT): Automatic UK tests: First automatic UK test - HMRC internal manual - GOV.UK✓ retrieved 2026-07-17
An individual will be resident in the UK if they spend 183 days or more in the UK in the relevant tax year. Open source ↗
An individual will be non-UK resident for a tax year if they were UK resident in one or more of the prior 3 tax years and spend fewer than 16 days in the UK; or if they were not UK resident in any of the prior 3 tax years and spend fewer than 46 days in the UK.
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ retrieved 2026-07-17
You’ll be non-UK resident for the tax year if you were resident in the UK for one or more of the 3 tax years before the current tax year, and you spen...Open source ↗
An individual working full-time overseas can be non-UK resident if they spend fewer than 91 days in the UK in the tax year, work more than 3 hours in the UK on fewer than 31 days, and have no significant break from overseas work.
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ retrieved 2026-07-17
You’ll be non-UK resident for the tax year if you work full-time overseas over the tax year and: you spend fewer than 91 days in the UK in the tax yea...Open source ↗
An individual has a 90-day tie for the tax year if they spent more than 90 days in the UK in either or both of the previous 2 tax years.
§ RFIG20570 - Statutory Residence Test (SRT): The ties test: 90-day tie - HMRC internal manual - GOV.UK✓ retrieved 2026-07-17
The individual will have a 90-day tie for the tax year if they have spent more than 90 days in the UK in either or both of the previous 2 tax years im...Open source ↗
The deeming rule applies where an individual has been UK resident in one or more of the 3 previous tax years, has at least 3 UK ties, and has been present in the UK on more than 30 days without being present at the end of the day (a qualifying day) in the tax year.
§ RFIG20720 - Statutory Residence Test (SRT): Days spent in the UK: The deeming rule - HMRC internal manual - GOV.UK✓ retrieved 2026-07-17
The deeming rule will apply to an individual for a tax year if they have: been UK resident in 1 or more of the 3 previous tax years · at least 3 UK ti...Open source ↗
The Cyprus '183-day rule' for tax residency is satisfied for individuals who spend more than 183 days in a calendar year in Cyprus, with no further conditions required.
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ retrieved 2026-07-17
The '183-day rule' for Cyprus tax residency is satisfied for individuals who spend more than 183 days in any one calendar year in Cyprus, without any ...Open source ↗
The Cyprus '60-day rule' requires that, cumulatively, the individual does not reside in any other single state for more than 183 days in aggregate, carries out business, employment, or holds a directorship of a Cyprus tax resident company during the tax year, and maintains a permanent residential property in Cyprus (owned or rented) during the tax year.
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ retrieved 2026-07-17
The '60-day rule' for Cyprus tax residency is satisfied for individuals who, cumulatively, in the relevant tax year: do not reside in any other single...Open source ↗
An individual without a Cyprus 'Domicile of Origin' is only considered domiciled in Cyprus for Special Defence Contribution (SDC) purposes once they have been a Cyprus tax resident for at least 17 out of the last 20 years prior to the relevant tax year.
§ Cyprus - Individual - Taxes on personal income✓ retrieved 2026-07-17
An individual who does not have a 'Domicile of Origin' in Cyprus (as defined in the Wills and Succession Law) is only considered to be domic...Open source ↗
As of 16 July 2015, individuals who are not domiciled in Cyprus for SDC purposes are exempt from SDC.
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
The following types of personal income are exempt from tax in Cyprus: As of 16 July 2015, individuals who are not domiciled in Cyprus for SDC purposes...Open source ↗
Dividend and interest income received by individuals is exempt from Personal Income Tax (PIT) in Cyprus but is instead subject to Special Defence Contribution (SDC).
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
Dividend and interest income (up to 31 December 2025 passive interest income) received by individuals are exempt from PIT but are subject to SDC. Open source ↗
For dividend income, SDC applies at 17% for profits of tax years up to 2025 (subject to certain grandfathering provisions) or 5% for profits of tax years from 2026 onward; interest income is subject to SDC at 17%, in place of PIT.
§ Cyprus - Individual - Taxes on personal income✓ retrieved 2026-07-17
For dividend (SDC rate of 17% for profits of tax years up to 2025, including certain grandfathering provisions or 5% for profits of tax years as from ...Open source ↗
For the 2025 to 2026 tax year, the qualifying net gain up to the lifetime limit is chargeable at the Business Asset Disposal Relief (BADR) rate of Capital Gains Tax of 14%.
§ HS275 Business Asset Disposal Relief (2026) - GOV.UK✓ retrieved 2026-07-17
For 2025 to 2026 this ‘net gain’, up to the lifetime limit, is then chargeable at the Business Asset Disposal Relief rate of CGT of 14%. Open source ↗
Where BADR applies to disposals falling on or after 6 April 2026, the rate applying is 18%.
§ CG64174 - Business Asset Disposal Relief: rates from April 2025 and from April 2026: anti-forestalling rule: unconditional contracts - HMRC internal manual - GOV.UK✓ retrieved 2026-07-17
Where BADR applies to disposals falling on or after 6 April 2026, the rate applying is 18%. Open source ↗
If BADR is claimed on a gain deferred until 11 March 2020 or later, it is subject to a reduced lifetime limit of £1 million.
§ HS275 Business Asset Disposal Relief (2026) - GOV.UK✓ retrieved 2026-07-17
Similarly, if you claim Business Asset Disposal Relief on a gain deferred until 11 March 2020 or later, it will be subject to the reduced lifetime lim...Open source ↗
To qualify for BADR, the individual must, for at least 2 years up to the date of sale, be an employee or office holder of the company (or one in the same group), with the company's main activities being trading (rather than non-trading activities such as investment) or being the holding company of a trading group.
§ Business Asset Disposal Relief: Eligibility - GOV.UK✓ retrieved 2026-07-17
Business Asset Disposal Relief means you’ll pay tax at either: 18% on all gains on qualifying assets disposed of from 6 April 2026 · 14% on all gains ...Open source ↗
§ Business Asset Disposal Relief: Eligibility - GOV.UK✓ retrieved 2026-07-17
To qualify, both of the following must apply for at least 2 years up to the date you sell your shares: you’re an employee or office holder of the comp...Open source ↗
If a higher or additional rate taxpayer, the individual will pay 24% Capital Gains Tax on gains from 6 April 2026.
§ Capital Gains Tax: what you pay it on, rates and allowances: Capital Gains Tax rates - GOV.UK✓ retrieved 2026-07-17
If you’re a higher or additional rate taxpayer, you’ll pay 24% on your gains from 6 April 2026. Open source ↗
For the 2026 to 2027 tax year, the Capital Gains Tax annual exempt allowance is £3,000.
§ Capital Gains Tax: what you pay it on, rates and allowances: Capital Gains Tax rates - GOV.UK✓ retrieved 2026-07-17
For the 2026 to 2027 tax year the allowance is £3,000, which leaves £49,600 to pay tax on. Open source ↗
The Capital Gains Tax rate applicable to Business Asset Disposal Relief and Investors' Relief increased from 10% to 14% for disposals made on or after 6 April 2025, and from 14% to 18% for disposals made on or after 6 April 2026.
§ Capital Gains Tax — rates of tax - GOV.UK✓ retrieved 2026-07-17
the rate of Capital Gains Tax that applies to Business Asset Disposal Relief and Investors’ Relief from 10% to 14% for disposals made on or after 6 Ap...Open source ↗
As of 1 January 2022, a new 50% exemption on remuneration applies for 'first employment' exercised in Cyprus by individuals who were not resident in Cyprus for at least 15 consecutive tax years immediately prior to commencing employment in Cyprus.
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
As of 1 January 2022, a new 50% exemption on remuneration applies for 'first employment' exercised in Cyprus by individuals who were not resident in C...Open source ↗
The 50% employment exemption requires that employment commence after 1 January 2022 and that remuneration exceed EUR 55,000 per annum.
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
As of 1 January 2022, a new 50% exemption on remuneration applies for 'first employment' exercised in Cyprus by individuals who were not resident in C...Open source ↗
For each individual, the 50% employment exemption applies once in their lifetime for a period of 17 years.
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
For each individual, the exemption will apply once in their lifetime for a period of 17 years. Open source ↗
As of 26 July 2022, a new 20% exemption on remuneration (up to a maximum of EUR 8,550 per annum) applies for first employments commencing after 26 July 2022.
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
As of 26 July 2022, a new 20% exemption on remuneration (up to a maximum amount of exemption of EUR 8,550 per annum) applies for first employments com...Open source ↗
The UK and Cyprus Double Taxation Convention was signed on 22 March 2018 in Nicosia and entered into force on 18 July 2018.
§ Cyprus: tax treaties - GOV.UK✓ retrieved 2026-07-17
The UK and Cyprus Double Taxation Convention was signed on 22 March 2018 in Nicosia. The convention entered into force on 18 July 2018. Open source ↗
An amending protocol to the Convention was signed on 19 December 2018 in Nicosia, entering into force on 2 October 2019 and effective in both countries from 1 January 2019.
§ Cyprus: tax treaties - GOV.UK✓ retrieved 2026-07-17
... An amending protocol to the UK and Cyprus Double Taxation Convention was signed on 19 December 2018 in Nicosia. This entered into force on 2 Octob...Open source ↗
The Convention is effective for income tax and capital gains tax for any year of assessment beginning on or after 6 April 2019, and for corporation tax for any financial year beginning on or after 1 April 2019.
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ retrieved 2026-07-17
... (ii) For income tax and capital gains tax for any year of assessment beginning on or after 6th April 2019; and · (iii) For corporation tax any fin...Open source ↗
Exposure by holding.
| Asset | United Kingdom | Cyprus | Planning issue | Exit-tax impact |
|---|---|---|---|---|
| Software company stake (~£1.8m planned sale, 2026) | UK Capital Gains Tax applies on disposal; Business Asset Disposal Relief (BADR) may reduce the effective rate to 14% for disposals in the 2025/26 tax year, rising to 18% for disposals on or after 6 April 2026, subject to a £1 million lifetime limit for gains deferred from 11 March 2020 onward. | Not established in verified research; Cyprus-side treatment for a sale occurring before relocation (2026 sale vs 2027 relocation) has not been confirmed and requires advisor review. | BADR eligibility depends on the individual being an employee/office holder of a trading company (or holding company of a trading group) for at least 2 years prior to sale; whether the stake is held directly or via a holding structure is unconfirmed and affects eligibility. The planned 2026 sale precedes the 2027 Cyprus relocation, meaning UK CGT/BADR rules are likely to apply rather than Cyprus rules. | No distinct UK exit tax regime was identified in verified research; the relevant impact is the BADR rate increase from 14% to 18% for disposals from 6 April 2026, and the standard higher/additional rate CGT of 24% from the same date if BADR does not apply. |
| Share portfolio and related dividend/interest income | Not detailed in verified UK-focused research for this route. | In Cyprus, dividend and interest income is exempt from Personal Income Tax but subject to Special Defence Contribution (SDC) at 17% for profits up to 2025 (or 5% for profits from 2026) unless the individual qualifies for the Cyprus non-domicile exemption, in which case SDC does not apply. | The non-domicile SDC exemption applies only until the individual has been Cyprus tax resident for at least 17 of the last 20 years; the location, listing status, and structure of the share portfolio holdings are unconfirmed and should be reviewed with an advisor to determine precise Cyprus-level treatment. | No exit tax trigger was identified in verified research for this asset class. |
UK-Cyprus Double Taxation Convention
The UK and Cyprus Double Taxation Convention governs the allocation of taxing rights over income and capital gains between the two states and has been in force since 2018, with an amending protocol effective from 2019.
Signed on 22 March 2018 in Nicosia; entered into force on 18 July 2018.
An amending protocol was signed on 19 December 2018 in Nicosia, entering into force on 2 October 2019 and effective in both countries from 1 January 2019.
Effective for income tax and capital gains tax for any year of assessment beginning on or after 6 April 2019, and for corporation tax for any financial year beginning on or after 1 April 2019.
A sequenced relocation roadmap.
- 01confirm with your advisor
Confirm company sale structure and BADR eligibility
Confirm whether the software company stake is held directly or via a holding structure, and verify the 2-year employee/office-holder and trading-company conditions required to qualify for Business Asset Disposal Relief ahead of the planned 2026 sale.
- 02fully supported
Execute company sale while UK resident (2026)
Complete the planned sale of the software company stake in 2026 while still UK tax resident, applying BADR if eligible; note the BADR rate is 14% for 2025/26 and rises to 18% for disposals on or after 6 April 2026, so timing within the tax year is relevant.
- 03fully supported
Monitor UK Statutory Residence Test ties ahead of departure
Track UK day counts against the automatic UK residence test (183 days), the 90-day tie, and the deeming rule (3+ UK ties and more than 30 qualifying days) in the lead-up to the planned 2027 relocation to establish a clear non-UK residence position.
- 04fully supported
Establish Cyprus tax residency (2027)
On relocation, establish Cyprus tax residency via either the 183-day rule or the 60-day rule (business/employment/directorship activity plus a maintained permanent residential property in Cyprus).
- 05confirm with your advisor
Assess Cyprus non-domicile SDC exemption
Confirm eligibility for the Cyprus non-domicile exemption from Special Defence Contribution, noting that domicile for SDC purposes only arises after at least 17 of the last 20 years of Cyprus tax residency, to determine treatment of dividend and interest income from the share portfolio.
- 06confirm with your advisor
Review UK-Cyprus Double Taxation Convention provisions
Review the 2018 UK-Cyprus Double Taxation Convention (in force 18 July 2018, amended by the 2018 protocol effective from 1 January 2019) for relief on any residual UK-source income or gains arising after relocation.
Advisor checklist.
- 01
Confirm current UK citizenship status.
- 02
Confirm current annual income level.
- 03
Confirm whether the software company stake is held directly or via a holding structure (affects BADR eligibility).
- 04
Confirm planned post-sale income strategy.
- 05
Confirm the nature and location (listing status) of the share portfolio holdings for accurate Cyprus CGT/SDC treatment.
- 06
Confirm whether any family members hold non-UK residency.
- 07
Confirm inheritance planning intentions or existing wills, and UK domicile-based IHT exposure post-relocation.
- 08
Confirm the timing and structure of the company sale (share sale vs asset sale) relative to the planned 2027 relocation.
- 09
Confirm the Cyprus residency visa/permit pathway for a UK citizen (non-EU national) post-Brexit.
- 10
Confirm current UK tax domicile status.
- 11
Confirm existence of any US person connections.
- 12
Confirm eligibility for Cyprus non-domicile SDC exemption and the 17-out-of-20-year test.
Dated source appendix.
- S01
§ RFIG20320 - Statutory Residence Test (SRT): Automatic UK tests: First automatic UK test - HMRC internal manual - GOV.UK✓ retrieved 2026-07-17
An individual will be resident in the UK if they spend 183 days or more in the UK in the relevant tax year. Open source ↗
- S02
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ retrieved 2026-07-17
You’ll be non-UK resident for the tax year if you were resident in the UK for one or more of the 3 tax years before the current tax year, and you spen...Open source ↗
- S03
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ retrieved 2026-07-17
You’ll be non-UK resident for the tax year if you work full-time overseas over the tax year and: you spend fewer than 91 days in the UK in the tax yea...Open source ↗
- S04
§ RFIG20570 - Statutory Residence Test (SRT): The ties test: 90-day tie - HMRC internal manual - GOV.UK✓ retrieved 2026-07-17
The individual will have a 90-day tie for the tax year if they have spent more than 90 days in the UK in either or both of the previous 2 tax years im...Open source ↗
- S05
§ RFIG20720 - Statutory Residence Test (SRT): Days spent in the UK: The deeming rule - HMRC internal manual - GOV.UK✓ retrieved 2026-07-17
The deeming rule will apply to an individual for a tax year if they have: been UK resident in 1 or more of the 3 previous tax years · at least 3 UK ti...Open source ↗
- S06
§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ retrieved 2026-07-17
This publication is available at https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-te...Open source ↗
- S07
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ retrieved 2026-07-17
The '60-day rule' for Cyprus tax residency is satisfied for individuals who, cumulatively, in the relevant tax year: do not reside in any ot...Open source ↗
- S08
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ retrieved 2026-07-17
The '183-day rule' for Cyprus tax residency is satisfied for individuals who spend more than 183 days in any one calendar year in Cyprus, without any ...Open source ↗
- S09
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ retrieved 2026-07-17
The '60-day rule' for Cyprus tax residency is satisfied for individuals who, cumulatively, in the relevant tax year: do not reside in any other single...Open source ↗
- S10
§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ retrieved 2026-07-17
For the purposes of both the '183-day rule' and the '60-day rule', days in and out of Cyprus are calculated as follows: the day of departure from Cypr...Open source ↗
- S11
§ Cyprus - Individual - Taxes on personal income✓ retrieved 2026-07-17
An individual who does not have a 'Domicile of Origin' in Cyprus (as defined in the Wills and Succession Law) is only considered to be domic...Open source ↗
- S12
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
The following types of personal income are exempt from tax in Cyprus: As of 16 July 2015, individuals who are not domiciled in Cyprus for SDC purposes...Open source ↗
- S13
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
Dividend and interest income (up to 31 December 2025 passive interest income) received by individuals are exempt from PIT but are subject to SDC. Open source ↗
- S14
§ Cyprus - Individual - Taxes on personal income✓ retrieved 2026-07-17
For dividend (SDC rate of 17% for profits of tax years up to 2025, including certain grandfathering provisions or 5% for profits of tax years as from ...Open source ↗
- S15
§ Cyprus - Individual - Taxes on personal income✓ retrieved 2026-07-17
However, on 13 September 2023, the Cypress Tax Authority (CTA) issued a Circular pursuant of which rental income from self-catering accommodation that...Open source ↗
- S16
§ Cyprus - Corporate - Income determination✓ retrieved 2026-07-17
Profits from disposals of corporate 'titles' are unconditionally exempt from CIT. 'Titles' are defined as shares, bonds, debentures, founders’ shares,...Open source ↗
- S17
§ Cyprus - Corporate - Withholding taxes✓ retrieved 2026-07-17
Under Cyprus legislation, there is no WHT on dividends and interest paid to non residents of Cyprus. Open source ↗
- S18
§ HS275 Business Asset Disposal Relief (2026) - GOV.UK✓ retrieved 2026-07-17
For 2025 to 2026 this ‘net gain’, up to the lifetime limit, is then chargeable at the Business Asset Disposal Relief rate of CGT of 14%. Open source ↗
- S19
§ CG64174 - Business Asset Disposal Relief: rates from April 2025 and from April 2026: anti-forestalling rule: unconditional contracts - HMRC internal manual - GOV.UK✓ retrieved 2026-07-17
Where BADR applies to disposals falling on or after 6 April 2026, the rate applying is 18%. Open source ↗
- S20
§ HS275 Business Asset Disposal Relief (2026) - GOV.UK✓ retrieved 2026-07-17
Similarly, if you claim Business Asset Disposal Relief on a gain deferred until 11 March 2020 or later, it will be subject to the reduced lifetime lim...Open source ↗
- S21
§ Business Asset Disposal Relief: Eligibility - GOV.UK✓ retrieved 2026-07-17
Business Asset Disposal Relief means you’ll pay tax at either: 18% on all gains on qualifying assets disposed of from 6 April 2026 · 14% on all gains ...Open source ↗
- S22
§ Business Asset Disposal Relief: Eligibility - GOV.UK✓ retrieved 2026-07-17
To qualify, both of the following must apply for at least 2 years up to the date you sell your shares: you’re an employee or office holder of the comp...Open source ↗
- S23
§ Capital Gains Tax: what you pay it on, rates and allowances: Capital Gains Tax rates - GOV.UK✓ retrieved 2026-07-17
If you’re a higher or additional rate taxpayer, you’ll pay 24% on your gains from 6 April 2026. Open source ↗
- S24
§ Capital Gains Tax: what you pay it on, rates and allowances: Capital Gains Tax rates - GOV.UK✓ retrieved 2026-07-17
For the 2026 to 2027 tax year the allowance is £3,000, which leaves £49,600 to pay tax on. Open source ↗
- S25
§ Capital Gains Tax — rates of tax - GOV.UK✓ retrieved 2026-07-17
the rate of Capital Gains Tax that applies to Business Asset Disposal Relief and Investors’ Relief from 10% to 14% for disposals made on or after 6 Ap...Open source ↗
- S26
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
As of 1 January 2022, a new 50% exemption on remuneration applies for 'first employment' exercised in Cyprus by individuals who were not resident in C...Open source ↗
- S27
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
For each individual, the exemption will apply once in their lifetime for a period of 17 years. Open source ↗
- S28
§ Cyprus - Individual - Income determination✓ retrieved 2026-07-17
As of 26 July 2022, a new 20% exemption on remuneration (up to a maximum amount of exemption of EUR 8,550 per annum) applies for first employments com...Open source ↗
- S29
§ Cyprus: tax treaties - GOV.UK✓ retrieved 2026-07-17
The UK and Cyprus Double Taxation Convention was signed on 22 March 2018 in Nicosia. The convention entered into force on 18 July 2018. Open source ↗
- S30
§ Cyprus: tax treaties - GOV.UK✓ retrieved 2026-07-17
... An amending protocol to the UK and Cyprus Double Taxation Convention was signed on 19 December 2018 in Nicosia. This entered into force on 2 Octob...Open source ↗
- S31
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ retrieved 2026-07-17
... (ii) For income tax and capital gains tax for any year of assessment beginning on or after 6th April 2019; and · (iii) For corporation tax any fin...Open source ↗
- S32
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ retrieved 2026-07-17
Notwithstanding the other provisions of this Convention, a benefit under this Convention shall not be granted in respect of an item of income or a cap...Open source ↗
- S33
§ 2018 UK-Cyprus Double Taxation Convention — in force - GOV.UK✓ retrieved 2026-07-17
This Convention shall apply to taxes on income and on capital gains imposed on behalf of a Contracting State or of its political subdivisions or local...Open source ↗
Published findings retain the live-fetched passage used for verification. Excluded items never enter the main analysis.
What did not survive verification.
9 evidence claims did not survive live-source verification. They are listed here and remain unpublished in the sections above.
- Q01confirm with your advisor
The SRT came into effect on 6 April 2013.
The cited quote did not support the figure§ RDR3: Statutory Residence Test (SRT) notes - GOV.UK✓ retrieved 2026-07-17
This publication is available at https://www.gov.uk/government/publications/rdr3-statutory-residence-test-srt/guidance-note-for-statutory-residence-te...Open source ↗
- Q02confirm with your advisor
As of 2017, an individual is a tax resident of Cyprus if one satisfies either the '183-day rule' or the '60-day rule' for the tax year.
The cited quote did not support the figure§ Cyprus - Individual - Residence - Worldwide Tax Summaries✓ retrieved 2026-07-17
The '60-day rule' for Cyprus tax residency is satisfied for individuals who, cumulatively, in the relevant tax year: do not reside in any ot...Open source ↗
- Q03confirm with your advisor
— Not applicable to a Cyprus non-dom for at least ~17 years given household's stated relocation in 2027. - Cyprus PIT worldwide basis:
No attached cited passage - Q04confirm with your advisor
UK exit-tax exposure / CGT rates on the £1.8m software company stake sale - Current BADR rate (as of the 2025/26 tax year, before relocation):
No attached cited passage - Q05confirm with your advisor
Rate rising from April 2026:
No attached cited passage - Q06confirm with your advisor
— This directly affects whether the stake is held directly or via a holding structure (a stated gap); confirm with your advisor. - Standard (non-BADR) higher-rate CGT from April 2026:
No attached cited passage - Q07confirm with your advisor
No UK "exit tax" in the sense of a deemed disposal on emigration exists for individuals generally; UK CGT is charge-on-realization based, but timing the sale (2026, pre-relocation) vs. deferring to post-2027 Cyprus residency is a critical sequencing lever — confirm with your advisor given anti-forestalling and temporary non-residence rules not fully explored here.
No attached cited passage - Q08confirm with your advisor
Special regimes — Cyprus 50%/20% employment exemptions (if any post-sale employment/directorship income arises) -
No attached cited passage - Q09confirm with your advisor
Gaps still requiring advisor confirmation - Whether the £1.8m stake qualifies for BADR (direct personal-company shareholding vs. holding-company structure) —
No attached cited passage
Reviewer block.
This public sample has not been countersigned. A named professional countersignature for flagship briefs is in preparation.
This brief is machine-generated orientation material, prepared for review with a qualified tax advisor. Published evidence claims are linked to passages fetched again during verification; the methodology is published on the TaxoTax “How we verify” page.