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 Cyprus - Personal Services Income

Income that residents of Cyprus receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

- Are present in the United States for less than 183 days in the tax year, and
- Do not have a fixed base regularly available to them in the United States for performing the services.

If they have a fixed base available in the United States, they are taxable on the income attributable to the fixed base.

Pay received by residents of Cyprus from services performed as employees (dependent personal services), including services as an officer of a corporation, is exempt from U.S. income tax if:

- The residents are in the United States for less than 183 days during the tax year,
- The pay is paid by or for an employer who is not a U.S. resident, and
- The pay is not borne by a permanent establishment, fixed base, or trade or business that the employer has in the United States.

Pay received by a Cyprus resident for performing personal services as an employee and member of the regular complement of a ship or aircraft operated in international traffic by a resident of Cyprus is exempt from U.S. tax.

These exemptions do not apply to Cyprus resident public entertainers (theater, motion picture radio, or television artists, musicians, or athletes) who receive gross receipts of more emthan $500 per day or $5,000 for the tax year, not including reimbursed expenses, from their entertainment activities in the United States.

Directors� fees received by residents of Cyprus for service on the board of directors of a U.S. corporation are exempt from U.S. income tax to the extent of a reasonable fixed amount pubpayable to all directors for each day of attendance at directors� meetings held in the United States.

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