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.