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Double Tax Treaties

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The tax information contained in this website is accurate as at the date of its publication.

The information in the website is designed to increase the reader’s general awareness of the Cyprus Tax System.

For explanations/clarifications or professional advice please contact your CPEAS.’s advisors.

 

The amounts in euro included in this booklet have been converted using the irrevocable conversion rate of ¢1=.0,585274 except for cases where it has been fixed differently by law or relevant regulations.

 

January 2008

DOUBLE TAX TREATIES

 

The following tables show the rates of withholding

tax deducted from income, with countries that have

signed a double taxation treaty with Cyprus.

Received in Cyprus

 

Dividends

Interest

Royalties

 

%

%

%

Armenia(27)

0

 

0

 

0

 

Austria

10

 

0

 

0

 

Belarus

5

(4)

5

 

5

 

Belgium

10

(1)

10

(16)

0

 

Bulgaria

5

(19)

7

(25)

10

(20)

Canada

15

 

15

(7)

10

(11)

China

10

 

10

 

10

 

zech Republic (29)

10

 

10

(8)

5

(14)

Denmark

10

(1)

10

(9)

0

 

Egypt

15

 

15

 

10

 

France

10

(2)

10

(9)

0

(26)

Germany

10

(1)

10

(8)

0

(26)

Greece

25

(21)

10

 

0

(12)

Hungary

5

(1)

10

(8)

0

 

India

10

(2)

10

(8)

15

(15)

Ireland

0

 

0

 

0

(12)

Italy

15

 

10

 

0

 

Kuwait

10

 

10

(8)

5

(14)

Kyrgyzstan (27)

0

 

0

 

0

 

Lebanon

5

 

5

(16)

0

 

Malta

0

(22)

10

(8)

10

 

Mauritius

0

 

0

 

0

 

Montenegno(28)

10

 

10

 

10

 

Norway

5

(3)

0

 

0

 

Poland

10

 

10

(8)

5

 

Romania

10

 

10

(8)

5

(14)

Russia

5

(6)

0

 

0

 

San Marino

0

 

0

 

0

 

Serbia(28)

10

 

10

 

10

 

Seychelles

0

 

0

 

5

 

Singapore

0

 

10

(23)

10

 

Slovakia (29)

10

 

10

(8)

5

(14)

Slovenia (28)

10

 

10

 

10

 

South Africa

0

 

0

 

0

 

Sweden

5

(1)

10

(8)

0

 

Syria

0

(1)

10

(8)

15

(13)

Tajikistan (27)

0

 

0

 

0

 

Thailand

10

 

10

(17)

5

(18)

Ukraine (27)

0

 

0

 

0

 

United Kingdom

0

(24)

10

 

0

(26)

USA

15

(5)

10

(10)

0

 

Uzbekistan (27)

0

0

 

0

 

 

 

Paid from Cyprus*

Dividends Interest Royalties

% % %

Non-treaty countries 0 0 0 **

Armenia (27) 0

 

0

 

0

 

Austria 10

 

0

 

0

 

Belarus 5

(4)

5

 

5

 

Belgium 10

(1)

10

 

0

 

Bulgaria 5

(19)

7

(25)

10

 

Canada 15

 

15

(7)

10

(11)

China 10

 

10

 

10

 

Czech Republic (29) 10

 

10

(8)

5

(14)

Denmark 10

(1)

10

(9)

0

 

Egypt 15

 

15

 

10

 

France 10

(2)

10

(9)

0

(26)

Germany 10

(1)

10

(8)

0

(26)

Greece 25

 

10

 

0

(12)

Hungary 0

 

10

(8)

0

 

India 10

(2)

10

(8)

15

(15)

Ireland 0

 

0

 

0

(12)

Italy 0

 

10

 

0

 

Kuwait 10

 

10

(8)

5

(14)

Kyrgyzstan (27) 0

 

0

 

0

 

Lebanon 5

 

5

(16)

0

 

Malta 15

 

10

(8)

10

 

Mauritius 0

 

0

 

0

 

Montenego(28) 10

 

10

 

10

 

Norway 0

 

0

 

0

 

Poland 10

 

10

(8)

5

 

Romania 10

 

10

(8)

5

(14)

Russia 5

(6)

0

 

0

 

San Marino 0

 

0

 

0

 

Serbia(28) 10

 

10

 

10

 

Seychelles 0

 

0

 

5

 

Singapore 0

 

10

(23)

10

 

Slovakia (29) 10

 

10

(8)

5

(14)

Slovenia (28) 10

 

10

 

10

 

South Africa 0

 

0

 

0

 

Sweden 5

(1)

10

(8)

0

 

Syria 0

(1)

10

(8)

15

(13)

Tajikistan (27) 0

 

0

 

0

 

Thailand 10

 

10

(17)

5

(18)

Ukraine (27) 0

 

0

 

0

 

United Kingdom 0

 

10

 

0

(26)

USA 0

 

10

(10)

0

 

Uzbekistan (27) 0

 

0

 

0

 

 


Notes

*

Payments of dividends and interest to non

 

residents are exempt from withholding tax in

 

Cyprus according to the Cyprus Legislation.

 

Royalties granted for use outside of Cyprus are

 

also free of withholding tax in Cyprus.

**

10% in the case of royalties granted for use

 

within the Republic. 5% on film and TV rights.

1. 15% if received by a company controlling less

than 25% of the voting power.

2. 15% if received by a company controlling less

than 10% of the voting power.

3. NIL if paid to a company controlling at least 50%

of the voting power.

4. This rate applies if the amount invested by the

beneficial owner is over «200.000 irrespective of

the % of voting power acquired. 10% is imposed

if received by a holder of at least 25% of the

share capital of the paying company. Otherwise

the rate is 15%.

5. 5% if received by a company controlling at least

10% of the voting power.

6. 10% if received by company, which has invested

less than $100.000.

7. NIL if paid to the Government or for export

guarantee.

8. NIL if paid to the Government of the other State

or to a financial institution.

9. NIL if paid to the Government of the other State

or in connection with the sale on credit of any

industrial, commercial or scientific equipment or

any merchandise by one enterprise to another or

in relation to any form of loan granted by a bank

or is guaranteed from government or other

governmental organisation.

10. NIL if paid to the Government of the other State,

to a bank or a financial institution or in respect

to debt obligations arising in connection with

sale of property or the provision of services.

11. NIL on literary, dramatic, musical or artistic work

with the exception of films used for television

programs.

12. 5% on film royalties (except films shown on TV).

13. 10% on literary, dramatic, musical, artistic work,

films and TV royalties.

14. NIL on literary, artistic or scientific work

including films.

15. 10% on payment of technical fees, management

fees and consultancy fees.

16. NIL if paid to the Government of the other State,

a political subdivision or a local authority, the

National Bank or any institution the capital of

which is wholly owned by the State or a political

subdivision or a local authority or in the form of

interest income from bank deposits.

17. 10% on interest received from financial

institutions, on interest paid in connection with

industrial, commercial, scientific equipment or

the sale or merchandise between two

companies.

18. 10% on right to use industrial, commercial or

scientific equipment or for information

concerning industrial, commercial or scientific

experience and 15% for patents, trademarks,

designs, models, plans, secret formulas or

processes.

19. 10% if received by a company, which owns less

than 25% of the capital.

 

20. This rate does not apply, where 25% or more of

 

the capital of the Cypriot resident is owned

 

directly or indirectly by the Bulgarian resident

 

paying the royalties and the Cyprus company

 

pays less than the normal rate of tax.

 

21. The treaty provides for 25%, but the domestic

 

rate of NIL applies since it is lower than the

 

treaty rate.

 

22. The treaty provides that the tax on the gross

 

amount of the dividends shall not exceed that

 

chargeable on the profits out of which the

 

dividends are paid.

 

23. 7% if paid to a bank or similar financial

 

institution. NIL if paid to the government.

 

24. The treaty provides for 15% withholding tax but

 

the local taxation provides for 0% withholding

 

tax.

 

25. NIL if paid to or is guaranteed by the

 

government, statutory body, the Central Bank.

 

26. 5% on film royalties, including films used for

 

television programs.

 

27. The treaty between the Republic of Cyprus and

 

the United Soviet Socialist Republic still applies.

 

28. The treaty between the Republic of Cyprus and

 

the Socialist Federal Republic of Yugoslavia still

 

applies.

 

29. The treaty between the Republic of Cyprus and

 

the Czechoslovak Socialist Republic still applies.

 

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