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Double Tax Treaties

Cyprus has entered into numerous Double Tax Treaties agreements.

Below shows the rates of withholding tax deducted from income, with countries that have signed a double tax treaty with Cyprus.

CYPRUS DOUBLE TAX TREATIES

Cyprus Double Tax Treaties

Remarks:

  1. Under Cyprus Legislation there is no withholding tax on dividends,interests and royalties paid to non-residents of Cyprus.
  2. In case where royalties are earned on rights used within Cyprus there is withholding tax of 10%.
  3. 5% on film and TV royalties.
  4. Nil if paid to a Government or for expert guarantee.
  5. Nil on literary, dramatic, musical or artistic work.
  6. Nil if paid to a Government of the other state.
  7. This rate applies for patents, trademarks, designs or models, plans, secret formulas or processes, or any industrial, commercial or scientific equipment,or for information concerning industrial, commercial or scientific experience.
  8. 15% if received by a company controlling less than 25% of the voting poweror by an individual.
  9. 15% if received by a person controlling less than 10% of the voting power.
  10. Nil if paid to a Government bank or financial institution.
  11. The treaty provides for withholding taxes on dividends but Greece does notimpose any withholding tax in accordance with its own legislation.
  12. 5% on film royalties (apart from films broadcasted on television).
  13. 5% if received by a person controlling less than 50% of the voting power.
  14. This rate applies to individual shareholders regardless of their percentage of shareholding.Companies controlling less than 10% of the voting shares are also entitled to this rate.
  15. 10% for payments of a technical, managerial or consulting nature.
  16. Treaty rate 15%, therefore restricted to Cyprus legislation rate.
  17. 10% if dividend paid by a company in which the beneficial owner has investedless than US $100.000.
  18. If investment is less than 200.000 euro, dividends are subject to 15% withholding tax which is reduced to 10% if the recipient company controls 25% or more of the paying company.
  19. No withholding tax for interest on deposits with banking institutions.
  20. Armenia, Kyrgyzstan, Tadzhikistan and Ukraine apply the USSR/Cyprus treaty.
  21. 10% on interest received by a financial institution or when it relates to sale on credit of any industrial, commercial or scientific equipment or of merchandise.
  22. This rate applies for any copyright of literary, dramatic, musical, artistic or scientific work.A 10% rate applies for industrial, commercial or scientific equipment. A 15% rate applies for patents, trademarks, designs or models, plans, secret formulae or processes.
  23. This rate applies to companies holding directly at least 25% of the share capitalof the company paying the dividend. In all other cases the withholding tax is 10%.
  24. This rate does not apply if the payment is made to a Cyprus international business entity by a resident of Bulgaria owning directly or indirectly at least 25% of the share capital of the Cyprus entity.
  25. 7% if paid to bank or financial institution.
  26. Montenegro, Serbia and Slovenia apply the Yugoslavia/Cyprus entity.
  27. The treaty is effective from 1 January 2009.
  28. This rate applies if received by a company (excluding partnership) which holds directly 25% of the shares. 10% applies in all other cases.
  29. 5% withholding tax applies where the company receiving the dividend owns at least 20% in the capital of the paying company or has invested an amount of at least EUR €100.000. In all others cases a withholding of 15% will apply.
  30. 5% withholding tax if the beneficial owner is a company holding at least 10% of the voting power of the capital of the company paying the dividend or 15% in all other cases.
  31. Nil of the beneficial owner is a company holding at least 10% of the capital of the company paying the dividend or 5% in all other cases.
  32. The treaty has been published in the government gazette but has not come into force until the time of publication of this booklet.