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Polish tax residence can continue where either the centre of personal or economic interests remains in Poland or the statutory day test is met. A Cyprus address, company or certificate does not override those domestic tests.

Polish tax residence can continue where either the centre of personal or economic interests remains in Poland or the statutory day test is met. A Cyprus address, company or certificate does not override those domestic tests.
The Polish Ministry of Finance describes two alternative domestic residence grounds: a centre of vital interests in Poland or presence exceeding 183 days in the tax year. If Cyprus also treats the person as resident, the Poland–Cyprus treaty must be applied to the facts.
Review Polish companies, partnerships, securities, real estate, employment, management activity, CFC exposure and departure or exit-tax rules before changing ownership. A Cyprus company managed from Poland can create Polish corporate residence or permanent-establishment risk. Dividend withholding and foreign-tax credits depend on beneficial ownership, treaty conditions, Polish anti-abuse rules and evidence; they are not automatically reduced to zero.
Primary checks: Polish Ministry of Finance tax-residence guidance and the official Poland–Cyprus convention.
Polish residence and the evidence trail. The Polish Ministry of Finance treats the centre of personal interests, the centre of economic interests and the 183-day test as alternative domestic connecting factors. Map family, homes, work, management, banking and investment activity for the whole departure year; a Cyprus certificate alone does not displace a Polish connection.
Treaty, pensions and companies. Use the current Poland–Cyprus convention, together with any amendments and domestic law, to classify private and government pensions, Polish real estate, dividends, interest, employment and business profits. Separately test beneficial ownership, withholding, foreign-tax credits, CFC exposure, exit tax, effective management and permanent establishments before changing a Polish company or investment structure.
EU route and evidence. A Polish national uses Cyprus's EU/EEA/Swiss MEU1 registration route for residence beyond three months and applies within four months of entry if the conditions are met; this is not a tax-residence certificate. European coordination rules normally subject a worker to one social-security system according to the actual work pattern. Retain the Polish residence analysis, treaty classification, company decision log, MEU1 and any A1/S1 records.
Cyprus-side reference. 2026: For the current Cyprus day tests, SDC/GHS boundaries and our advisory scope, use the Cyprus tax-residence and non-dom guide and tax-residence and non-dom service. This page remains focused on the departure-country, treaty and cross-border decisions that are specific to this route.
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Evie Sophia Iordanou
Associate

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