A British couple living in Manchester want to buy a holiday flat in Paphos. Since Brexit, what do they need?
- Nothing, they buy like any EU citizen
- A golden visa first
- A purchase permit under Cap. 109, filed on form COMM 145 with the Paphos District Administration
- Approval from the Real Estate Agents Registration Council
Since Brexit, British buyers are non-EU and need a Cap. 109 permit from the District Administration where the property lies. There is no fee and a complete file usually takes two to three weeks.
Papacleovoulou: Cap. 109 permits for non-EU buyers (2026-09) A Greek buyer from Athens asks if he needs a permit to buy an apartment in Nicosia. What is the answer?
- No, EU and EEA citizens buy on the same terms as Cypriots
- Yes, every foreigner needs form COMM 145
- Yes, but only above EUR 300,000
- Only if he does not live in Cyprus
Greece is an EU member, so a Greek buyer needs no purchase permit. Greeks are in fact the largest foreign buyer group in Nicosia.
Papacleovoulou: Cap. 109 permits for non-EU buyers (2026-09) An Israeli couple want to buy two apartments in Larnaca now and a third next year as rental investments. What should you tell them?
- There is no limit for non-EU buyers
- Each spouse can buy three units separately
- They must buy through a Cyprus company to buy more
- Ministry policy normally allows up to two units per non-EU buyer, and a couple counts as one buyer, so a third unit is unlikely to be approved
Under Cap. 109 policy a non-EU buyer can normally hold one home or up to two units, such as two homes, and a married couple counts as one buyer. Set expectations early and refer them to a lawyer before they reserve a third unit.
Papacleovoulou: Cap. 109 permits for non-EU buyers (2026-09) An Israeli client asks: 'Can I sign the contract before my COMM 145 permit is granted?' What is accurate?
- No, signing without a permit is illegal
- Yes, he can sign and lodge the contract, but the title cannot be registered in his name until the permit is granted
- Yes, and the title transfers immediately
- Only if he pays the full price in cash
The buyer can sign and lodge the sale contract with the Land Registry first, which protects his interest. Only the transfer of title waits for the permit.
Koufettas Law: Buying property in Cyprus, a foreigner's legal guide (2026-10) A Lebanese investor suggests buying four flats through a new Cyprus company he owns, 'so the foreigner limit does not apply'. What do you answer?
- Good idea, companies are always treated as Cypriot
- It works if a Cypriot is named as director
- A Cyprus company controlled by non-EU persons is caught by the same Cap. 109 rules, so the limit still applies
- Companies need no permit but pay double transfer fees
The Aliens Law looks through to control: a Cyprus company controlled by non-EU persons needs a permit just like the individual. Never suggest structures to get around the rules, and send him to a lawyer.
Papacleovoulou: Cap. 109 permits for non-EU buyers (2026-09) A Russian-speaking client asks how much he must invest in property for Cyprus permanent residence under Regulation 6(2). What is the rule since May 2023?
- At least EUR 300,000 plus VAT in new homes bought from a developer, paid upfront with funds from abroad
- EUR 500,000 in any resale property
- EUR 2 million, which also gives citizenship
- EUR 150,000 in a rental property
Since 2 May 2023 the residential route needs at least EUR 300,000 plus VAT in new homes from a developer, paid in full and funded from abroad, plus a secure annual income. In September 2026 the government said the scheme would be tightened before Schengen entry, so always check the latest rules.
GK Law Firm: Cyprus permanent residency in 2026 (2026-10) A Ukrainian couple with two children apply for Regulation 6(2) permanent residence. What minimum secure annual income must they show, in EUR?
EUR EUR 50,000 for the applicant + EUR 15,000 for the spouse + 2 x EUR 10,000 for the children = EUR 85,000 a year.
Kyprianou: 2023 amendments to the Regulation 6(2) permanent residence scheme (2023-05) A Ukrainian client has just received investor permanent residence and wants to take a job at a Limassol tech company. What should you tell him?
- The permit lets him work anywhere in Cyprus
- He can work only for the developer he bought from
- He can work after one year
- Holders of the investor permanent residence permit may not work in Cyprus, so he needs separate advice on a work permit route
The investor permit is a residence permit, not a work permit. Employment needs a separate route, such as a company of foreign interests hiring highly skilled staff, so refer him to an immigration lawyer.
Zeno Legal: Cyprus work permits for non-EU nationals, 2026 (2026-08) A client says a friend 'got a Cyprus passport by buying a villa'. Can he do the same in 2026?
- Yes, with EUR 2 million in property
- No, the citizenship-by-investment programme was scrapped in November 2020, and Parliament repealed the cabinet's power to grant investor citizenship in December 2025
- Yes, through Regulation 6(2)
- Only if he also donates to a charity
The scheme closed in 2020 after an Al Jazeera investigation, after 7,329 people had received passports. Today property can lead only to permanent residence, never to a passport through investment.
Cyprus Mail: Cyprus ends cabinet power to grant golden passports (2025-12) Your buyer is about to sign an off-plan contract in Limassol. Since December 2023, which Land Registry document must accompany every sale contract?
- A title deed in the buyer's name
- A building permit copy
- A search certificate no more than five working days old, showing mortgages or charges on the plot
- A valuation report from the bank
Law 132(I)/2023, in force since 12 December 2023, requires a fresh search certificate with every contract. It shows whether a bank mortgage or other charge sits on the land, which is vital before paying a developer.
Koufettas Law: Buying property in Cyprus, a foreigner's legal guide (2026-10) A British buyer has signed his sale contract. What should his lawyer do next to protect him against the seller selling or mortgaging the unit to someone else?
- Lodge the contract with the Land Registry within six months of signature, for a EUR 50 fee
- Send it to the District Administration
- Nothing until the title deed is issued
- Register it with the Real Estate Agents Council
Lodging under Law 81(I)/2011 registers the buyer's interest, blocks other sales or mortgages and lets him sue for transfer. After six months a court order is needed.
Koufettas Law: Buying property in Cyprus, a foreigner's legal guide (2026-10) A buyer loves a 2012 resale apartment in Paphos, but it still has no separate title deed. What usually has to happen before separate deeds can be issued?
- The buyer simply applies with his passport
- The agent files a request with the Council
- The seller pays capital gains tax first
- The building authority issues a certificate of approval, every bank with a mortgage on the land consents, and the developer files a complete division file
Deed delays usually come from deviations from approved plans, unmet planning conditions or unpaid developer loans. Ask the buyer's lawyer to check the search certificate, planning status and any mortgage before he commits.
Koufettas Law: Title deeds in Cyprus (2026) (2026-10) A new client wants to pay EUR 900,000 for a villa, refuses to explain where the money comes from and asks you to 'keep it simple'. What must you do?
- Go ahead, source of funds is the bank's job
- Tell him you will report him unless he explains
- Apply enhanced checks; if the suspicion remains, report it to MOKAS without telling the client
- Ask the seller to accept a cash discount
Estate agents are obliged entities under AML Law 188(I)/2007. They must identify clients, check source of funds for higher risk and report suspicions to MOKAS, the financial intelligence unit, without tipping off the client.
Kourtellos & Co: Anti-money laundering in Cyprus and the EU single rulebook (2026-10) A corporate buyer registered abroad wants to buy an office. Under Cyprus AML rules, whom must you identify and verify, and who supervises agents today?
- Only the director who signs; MOKAS supervises
- The company, its representatives and its beneficial owners; the Real Estate Agents Registration Council supervises for now, with a draft law proposing the Tax Department
- Only the company's registration certificate; the Central Bank supervises
- Nobody, if the funds come from an EU bank
Agents must identify and verify clients and beneficial owners. The Council supervises agents today, but a draft amendment would move supervision of the real estate sector to the Tax Department ahead of the EU AML Regulation, which applies from 10 July 2027.
FFWD: What the new anti-money laundering law means for real estate (2026-01) A young couple will live in a new 150 sqm apartment priced at EUR 420,000 (planning application after October 2023). Can they claim the reduced 5% VAT for a permanent home?
- No, the home must be under 100 sqm
- Yes, at 5% on the first 130 sqm and first EUR 350,000, because the home is under 190 sqm and the total price is under EUR 475,000
- Yes, at 5% on the full price
- No, only Cypriot citizens qualify
Under Law 42(I)/2023 the 5% rate covers the first 130 sqm and EUR 350,000 for a home of up to 190 sqm costing no more than EUR 475,000; the rest is at 19%. Older projects may use the previous rule if the application deadlines are met.
Mondaq: Cyprus 5% VAT on primary residences, the 2026 amendment (Law 109(I)/2026) (2026-04) A buyer who got the 5% VAT rate on his new home tells you he plans to sell it after four years. What should you warn him about?
- Nothing, the relief is final once granted
- He will pay double transfer fees
- He loses his residence permit
- If the home is sold or let within ten years, part of the VAT saving must be repaid
The reduced rate is meant for a permanent home, so selling or letting within ten years triggers a partial repayment. Tell him to check the amount with his tax adviser before he plans the sale.
Mondaq: Cyprus 5% VAT on primary residences, the 2026 amendment (Law 109(I)/2026) (2026-04) A Dutch client asks why you do not show homes in Famagusta town or Kyrenia. What is the most professional answer?
- 'Those areas are dangerous, everyone gets scammed there'
- 'I am not allowed to talk about politics'
- 'We work only in the areas controlled by the Republic. Property in the north is a separate, high-risk market where titles are often disputed and dealing in Greek Cypriot-owned land is an offence under Republic law, so I always advise independent legal advice there'
- 'They are just too far from the airport'
Stay factual and calm, without political comment. A 2006 amendment makes dealing in such property punishable by up to seven years in prison, so the risk is legal, not only commercial.
Koufettas Law: Buying property in Cyprus, a foreigner's legal guide (2026-10) You introduced a buyer to a seller but never agreed a fee in writing. The sale completes. What does the Real Estate Agents Law say?
- You get nothing without a written agreement
- Where no fee was agreed, the commission is 3% of the transaction value, payable on completion, provided you are registered and licensed
- The fee is fixed at 1% plus VAT
- The buyer and seller decide after completion
Article 20 sets a default 3% when no fee is agreed, but any agency agreement with an unregistered or unlicensed person is invalid. Still, always agree the fee in writing upfront.
Business in Cyprus: Real Estate Agents Law 71(I)/2010, consolidated English text (2020-07) A British buyer says: 'Prices in Cyprus have gone up so much, I will wait a year.' What is the best first response?
- 'Prices will double next year, buy now'
- 'Fine, call me when you are ready'
- 'Waiting is always a mistake'
- Acknowledge the concern, ask what he wants the property for and his timeline, then share recent official price data and let him decide
Good objection handling starts with listening and questions, then facts, never pressure or price predictions. Cite official sources such as the Central Bank index and let the client choose.
A Lebanese investor asks you to 'guarantee 8% net' on a Limassol apartment. What do you answer?
- Never guarantee returns; explain that the RICS and KPMG index showed gross apartment yields of about 5.51% in Q2 2026, and build a realistic net estimate together
- 'Yes, 8% is normal in Limassol'
- 'I can guarantee it if he signs today'
- 'Yields do not exist in Cyprus'
Promising returns is unprofessional and can mislead. Use published data, then deduct costs such as common charges, management, vacancy and tax to give an honest net figure.
Papacleovoulou: Cyprus property market trends 2026 (CBC and RICS/KPMG data) (2026-09) - Dubai areas
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