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Capital Hub: Discover how Cyprus and Montenegro are attractive to investors

Tax department clarifies Cyprus 60-day rule for nominee directors

Effective as of 1 January, 2017, the so-called “60 day rule” for the purposes of establishing Cyprus tax residency for individuals is of importance to those seeking Cypriot residency.

Under the rule, individuals are considered tax residents of Cyprus and benefit from the island’s tax regime if they:

• Reside in Cyprus for a period of 60 days

• Do not reside in any other single country for a period exceeding 183 days in total

• Are not tax resident in any other country

• Have ties with Cyprus (i.e. are business owners, employees or directors) during the year in question

• Are owners or tenants of a residential property in Cyprus

The tax department issued an additional circular on 29 January, 2019 to clarify a specific case. In the event of a nominee directorship, the tax department will deem that the fourth condition has not been met; therefore the residency status will not be obtained. 

It is worth noting that the 183 day rule remains unchanged. This means that individuals can fulfill either the “183 day rule” criteria or the “60 day rule” criteria in the tax year and if necessary they can obtain the relevant certificate from the tax authorities.

If you have any further queries, please contact Eurofast’s experienced Citizenship and Residency team which can provide full guidance and assistance related to the Cyprus tax residency procedure. 

Maria Elia Fotsios, Eurofast Cyprus maria.elia@eurofast.eu

 

Montenegro is a new home for global citizens

A tiny Mediterranean country, settled between the borders of ex-Yugoslavian member states, is in the spotlight for its rapid and sustainable growth.

The beautiful blend of stunning mountains and clear sea, combined with an average of 240 sunny days per year, makes Montenegro a destination attractive for tourists, investors and global citizens alike. Since the country gained its independence in 2006, many steps towards continuous prosperity have been made. Today, Montenegro is an EU candidate country and it joined NATO as its 
29th member state in 2017.

Political aspects—heavily improved in the last couple of years—are of immense importance as well, including stability, economic growth, security, legacy, and quality of living. Infrastructural development is a key driver for progress across Montenegro and a critical enabler for productivity and sustainable economic growth. In this sector, the country has marked incredible progress. From highway development with a total worth of €1.1 billion to a submarine power cable between Montenegro and Italy, a wide range of projects seem to pave the way towards a prosperous future. The value of the biggest investment projects varies from €400 million to €1.1 billion and has brought Montenegro to the centre of attention of many media and various stakeholders.

For businessmen and investors, the corporate tax rate of just 9% is a clear signal of a positive investment climate. Furthermore, property tax ranges between 0.01% and 1% while real estate transfer tax rate is 3%.

Since its independence, many appreciative investors from various countries have chosen Montenegro as their second home. This inspired the government of Montenegro to create a unique Citizenship by Investment Programme which began on 1 January, 2019.

The programme is designed to last for three years and will accept up to 2,000 applications. It supports the development of the northern and coastal region, tourism development in all regions, and will be transparent. Taking this into consideration, the development project should be a hotel or mixed complex. The list of approved projects will be published by the governmental authority. Applications will be submitted and processed through a certified agent, and the application criteria are defined as follows:

• €15,000 for the applicant fee

• €10,000 for each family member, not exceeding four family members

• €50,000 for each following family member

• €100,000 Governmental Fund Donation

• Investment amount of €450,000 in a development project in the capital city of Podgorica or the coastal region or €250,000 for the purpose of investing in a development project in the northern or central region of Montenegro, excluding Podgorica

• Proof of the origin of the funds

• Satisfactory due-diligence check

Passport holders will enjoy the benefits of citizenship by being granted visa-free entry to 123 countries, making them truly 
global citizens in their new home of Montenegro. 

 

 

 

For more information, contact:

Bojana Minic, Investment and Immigration Consultant at Eurofast bojana.minic@eurofast.eu

Content provided by Eurofast - Please find Eurofast disclaimer at eurofast.eu/disclaimer


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