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
- Under Cyprus Legislation there is no withholding tax on dividends,interests and royalties paid to non-residents of Cyprus.
- In case where royalties are earned on rights used within Cyprus there is withholding tax of 10%.
- 5% on film and TV royalties.
- Nil if paid to a Government or for expert guarantee.
- Nil on literary, dramatic, musical or artistic work.
- Nil if paid to a Government of the other state.
- 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.
- 15% if received by a company controlling less than 25% of the voting poweror by an individual.
- 15% if received by a person controlling less than 10% of the voting power.
- Nil if paid to a Government bank or financial institution.
- The treaty provides for withholding taxes on dividends but Greece does notimpose any withholding tax in accordance with its own legislation.
- 5% on film royalties (apart from films broadcasted on television).
- 5% if received by a person controlling less than 50% of the voting power.
- 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.
- 10% for payments of a technical, managerial or consulting nature.
- Treaty rate 15%, therefore restricted to Cyprus legislation rate.
- 10% if dividend paid by a company in which the beneficial owner has investedless than US ＄100.000.
- 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.
- No withholding tax for interest on deposits with banking institutions.
- Armenia, Kyrgyzstan, Tadzhikistan and Ukraine apply the USSR/Cyprus treaty.
- 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.
- 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.
- 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%.
- 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.
- 7% if paid to bank or financial institution.
- Montenegro, Serbia and Slovenia apply the Yugoslavia/Cyprus entity.
- The treaty is effective from 1 January 2009.
- This rate applies if received by a company (excluding partnership) which holds directly 25% of the shares. 10% applies in all other cases.
- 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.
- 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.
- 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.
- The treaty has been published in the government gazette but has not come into force until the time of publication of this booklet.