Most countries use a 183-day threshold for tax residency, but a smaller group of jurisdictions has codified pathways that can establish tax residency with 90 days or fewer of presence. These routes are not simple day-count loopholes: they usually require residence permits, investment, local housing, business ties, lump-sum tax payments, or other evidence of economic connection.
Tax residency in a destination country is only one side of the analysis. A person’s home country may still claim them as tax resident under its own rules. Treaty tie-breakers, exit taxes, forced-residency presumptions, and center-of-life tests can override or weaken the value of a low-day foreign tax residency claim.
The source introduction lists Cyprus, the United Arab Emirates, the Bahamas, Mauritius, and Andorra, but the third country discussed in detail is Anguilla rather than the Bahamas. This inconsistency is unclear.
Cyprus: 60 days
Cyprus has one of the lowest day-count tax residency rules in the European Union.
Under the 60-day rule, codified in 2017 and refined by the December 2025 tax reform, an individual can qualify as a Cyprus tax resident in a tax year by meeting four conditions:
- spend at least 60 days in Cyprus during the calendar year;
- not spend more than 183 days in any single other country;
- carry on a business in Cyprus, hold employment in Cyprus, or hold a directorship in a Cyprus tax-resident company that does not terminate during the year;
- maintain a permanent residence in Cyprus, owned or rented, available for personal use.
The 2026 reform removed the previous requirement to prove that the person was not tax resident anywhere else. From January 1, 2026, dual tax residency conflicts are handled through double tax treaty tie-breaker rules rather than automatically disqualifying the Cyprus claim.
Once tax resident, an individual can apply for non-domiciled status. Cyprus non-doms are exempt from the Special Defence Contribution on worldwide dividend and passive interest income for up to 17 years from the date they become Cyprus tax resident.
The non-dom exemption ends once the person has been a Cyprus tax resident for 17 of the previous 20 years, at which point they become deemed domiciled.
Cyprus also has:
- no inheritance tax;
- no wealth tax;
- no gift tax;
- capital gains tax only on gains from Cypriot real estate and shares in companies whose value derives from Cypriot real estate;
- no capital gains tax on general securities or foreign property;
- a €22,000 tax-free threshold for earned income under the 2026 reform.
Earned income remains subject to standard progressive income tax.
Cyprus is accessible through Larnaca International Airport, with direct flights from cities including London, Frankfurt, Vienna, Athens, Dubai, and Tel Aviv.
United Arab Emirates: 90 days
The United Arab Emirates introduced its first codified individual tax residency framework through Cabinet Decision No. 85 of 2022, effective March 1, 2023.
The UAE has three independent tests for tax residency. Meeting any one of them can establish UAE tax residency:
- principal place of residence and center of financial and personal interests in the UAE;
- physical presence in the UAE for 183 days or more across a consecutive 12-month period;
- physical presence in the UAE for 90 days or more across a consecutive 12-month period, plus additional conditions.
The 90-day route applies only if the individual:
- holds UAE nationality, GCC nationality, or a valid UAE residence permit; and
- maintains a permanent place of residence in the UAE or carries on employment or business activity there.
Days are counted on a rolling 12-month basis, not by calendar year. Parts of a day count as full days. Exceptional circumstances beyond the individual’s control that prevent departure may be disregarded.
The UAE tax result is the main attraction:
- no personal income tax on individuals;
- no capital gains tax on personal investments;
- no wealth tax;
- no inheritance tax.
The 9% federal corporate tax introduced in 2023 applies only to business income above AED 375,000 per year. Personal investment activity is outside its scope.
For a UAE Golden Visa holder or standard UAE residence permit holder who can spend 90 days per year in the country and maintain a residence, the 90-day test can produce a Tax Residency Certificate for treaty use.
The main limitation is that the 90-day route is not available to everyone. Without a UAE residence permit, GCC nationality, or UAE citizenship, the 183-day test is the main domestic route.
Dubai International Airport provides direct service from many major global cities, making the UAE one of the most logistically straightforward options on the list.
Anguilla: 45 days
Anguilla’s High-Value Resident program, launched in 2019, has one of the lowest physical-presence requirements in the investment migration market.
The program is designed for ultra-high-net-worth individuals who divide their time across multiple jurisdictions and need a defensible tax residency for Common Reporting Standard self-certification.
Applicants must:
- own and maintain Anguillan real estate valued above $400,000;
- allocate at least $100,000 of that amount to land;
- pay an annual lump-sum worldwide income tax of $75,000 to the Anguilla Treasury;
- demonstrate the financial capacity to prepay the first five years of that obligation;
- spend at least 45 days per year in Anguilla;
- declare annually in writing that they have not spent more than 183 days in any other single country;
- maintain genuine ties such as a local bank account, club memberships, and an Anguillan driver’s license.
Fees include:
- $7,500 due diligence fee per adult applicant;
- $3,000 processing fee for a family of up to four.
Approval typically takes around three months.
Anguilla imposes no personal income tax, capital gains tax, inheritance tax, or corporate tax. The $75,000 annual lump sum effectively caps the High-Value Resident’s tax liability on worldwide income.
The 45-day High-Value Resident program is separate from Anguilla’s citizenship pathway. Continuous physical residence may build toward British Overseas Territories Citizenship, but that usually requires around 270 days per year on the island over five years, far above the 45-day tax residency requirement.
It is also separate from Anguilla’s Residence-by-Investment program, which grants permanent residency through either:
- a $150,000 Capital Development Fund donation; or
- a $750,000 real estate investment.
That residence-by-investment route does not by itself establish tax residency.
Mauritius: 90 days averaged over three years
Mauritius does not have a special low-day tax residency program. Instead, its standard tax law contains an aggregate-day test.
Section 73 of the Mauritius Income Tax Act sets out three independent tax residency tests:
- 183 days or more in Mauritius in a single income year;
- 270 days or more across the current income year and the two preceding income years;
- Mauritius domicile, subject to an exception for people whose permanent place of abode is elsewhere.
The 270-day aggregate test is the relevant low-day route. Spread evenly, 270 days over three years averages 90 days per year.
A person spending roughly three months per year in Mauritius for three consecutive years can qualify as a Mauritius tax resident under domestic law from year three onward.
The Mauritian income year runs from July 1 to June 30, not by calendar year. Day counts are usually based on entry and exit records held by the Mauritius Passport and Immigration Office, which the Mauritius Revenue Authority can consult.
Tax-resident individuals are taxed on:
- Mauritian-source income directly;
- foreign-source income only when remitted to Mauritius.
Section 73B(2) of the Income Tax Act, introduced through the Premium Visa framework, states that spending in Mauritius through a foreign credit or debit card is deemed not to have been remitted to Mauritius.
For income that enters the Mauritian tax net, post-July 2025 rates are:
- 0% on the first MUR 500,000;
- 10% on the next MUR 500,000;
- 20% above MUR 1 million.
The Finance Act 2025 added a 15% Fair Share Contribution for individuals with annual net income above MUR 12 million. This can raise the effective top rate to 35% through June 2028, but only on remitted income.
The Mauritius Premium Visa, available to remote workers and retirees, is commonly used with the 270-day test. The visa itself does not trigger tax residency; the day count does.
Investors seeking immediate permanent residency rather than a renewable visa can use the Mauritius Permanent Residency Permit through a $375,000 real estate investment.
SSR International Airport has direct services from Paris, London, Dubai, Johannesburg, Hong Kong, Singapore, and Mumbai.
Andorra: 90 days, with caveat
Andorra’s passive residency permit, formally Residence Without Lucrative Activity, requires a minimum stay of 90 days per calendar year.
The 90-day requirement remained in place after the January 2026 Omnibus 2 reform, which raised the passive residency investment threshold to €1,000,000, plus:
- a non-refundable €50,000 state fee for the main applicant;
- €12,000 per dependent.
The caveat is that the 90-day figure is an immigration requirement, not the full tax residency test.
Andorran tax law treats an individual as tax resident if they either:
- spend more than 183 days in Andorra during the calendar year; or
- have Andorra as the center of their economic activities or interests.
The center-of-economic-interests test is what can make a 90-day structure viable. Passive residents who organize their financial life around Andorra, such as by holding their primary investment portfolio there, drawing income from Andorran assets, and banking locally, may qualify as tax residents without meeting the 183-day threshold.
Verification has tightened since 2025. The Andorran tax authority now routinely requests evidence of effective day-to-day life in Andorra before issuing a tax residency certificate. This can include:
- bank statements;
- lease agreements;
- telecom records;
- local service receipts.
Once tax resident, Andorra offers:
- personal income tax capped at 10%;
- no wealth tax;
- no inheritance tax;
- no gift tax.
Capital gains on shares held more than ten years are exempt, as is foreign real estate held more than ten years. Gains on Andorran real estate follow a separate sliding scale, starting at 15% within the first two years and reducing to full exemption after ten years of ownership.
Andorra has double tax treaties with France, Spain, Portugal, Luxembourg, the UAE, and several other jurisdictions.
Andorra is not a fast citizenship route. It requires 20 years of residency and renunciation of any other nationality.
Andorra has no airport. Passive residents usually fly into Barcelona-El Prat or Toulouse-Blagnac and continue by road, normally a two-to-three-hour drive.
What low-day tax residency actually provides
Low-day tax residency does not automatically release someone from tax obligations elsewhere.
A person’s home country may still apply:
- treaty tie-breaker rules;
- exit taxes;
- forced-residency presumptions;
- center-of-life tests;
- long-arm fiscal rules.
Jurisdictions such as Italy, France, Spain, and Australia may challenge structures that appear “residency-free” or insufficiently connected to the claimed tax base.
For people from countries with broad tax claims, such as the United States or the post-2025 United Kingdom, a low-day tax residency in another jurisdiction will not by itself remove home-country tax exposure.
The practical value of these regimes depends on both sides of the structure: whether the destination country grants a credible tax residency position, and whether the person’s home country accepts that position under its own law and any applicable treaty.
Source article: www.imidaily.com
