Cyprus Double Tax Treaty Network

Cyprus Double Tax Treaty Network

For any further information please contact info@lsts.com.cy.

Paid from (1) WHT (%)
Dividends Interest Royalties
Treaty countries – Force Entry Date
Armenia – 19 Sep 2011 0/5 (2) 5 5
Austria – 11 Jan 2013 10 0 0
Belarus – 12 Feb 1999 5/10/15 (3) 5 5
Belgium – 8 Dec 1999 10/15 (4) 0/10 (5, 6) 0
Bosnia (7) – 8 Sep 1986 10 10 10
Bulgaria – 3 Jan 2001 5/10 (8) 0/7 (5, 9) 10 (9)
Canada – 3 Sep 1985 15 0/15 (10) 0/10 (11)
China, People’s Republic of – 5 Oct 1991 10 10 10
Czech Republic – 26 Nov 2009 0/5 (12) 0 0/10 (13)
Denmark – 7 Sep 2011 0/15 (5, 14) 0 0
Egypt – 14 Mar 1995 15 15 10
Estonia – 1 Jan 2014 0 0 0
Finland – 1 Jan 2014 5/15 (15) 0 0
France – 1 Apr 1983 10/15 (16) 0/10 (17) 0/5 (18)
Germany – 16 Dec 2011 5/15 (19) 0 0
Guernsey, The states of (47) 0 0 0
Greece – 16 Jan 1969 25 10 0/5 (20)
Hungary – 24 Nov 1982 5/15 (4) 0/10 (5) 0
Iceland (43) – 22 December 2014 5 (44) 0 5
India – 21 Dec 1994 10/15 (21) 0/10 (17) 15 (22)
Ireland, Republic of – 12 Jul 1970 0 0 0/5 (20)
Italy – 9 Jun 1983 15 10 0
Kuwait – 25 Sep 1986 0 0 5
Kyrgyzstan (48) – 26 Aug 1983 0 0 0
Lebanon – 14 Apr 2005 5 5 0
Lithuania (31) – 1 Jan 2015 0/5 (23) 0 5
Malta – 11 Aug 1994 0 10 10
Mauritius – 12 Jun 2000 0 0 0
Moldova – 03 Sep 2008 5/10 (25) 5 5
Montenegro (7) – 8 Sep 1986 10 10 10
Norway (32) – 1 Jan 2015 0/15 (40) 0 0
Poland – 11 Jan 2013 0/5 (24) 0/5 (5) 5
Portugal – 1 Jan 2014 10 10 10
Qatar – 20 Mar 2009 0 0 5
Romania – 8 Nov 1982 10 0/10 (5) 0/5 (26)
Russia – 2 Apr 2012 5/10 (27) 0 0
San Marino – 18 Jul 2007 0 0 0
Serbia (7) – 8 Sep 1986 10 10 10
Seychelles – 27 Oct 2006 0 0 5
Singapore – 8 Feb 2001 0 0/7/10 (5, 28) 10
Slovak Republic (41) – 30 Dec 1980 10 0/10 (5) 0/5 (26)
Slovenia – 14 Sep 2011 5 5 5
South Africa – 8 Dec 1998 0 0 0
Spain (30) – 1 Jan 2015 0/5 (29) 0 0
Sweden – 14 Nov1989 5/15 (4) 0/10 (5) 0
Switzerland (45) 0/15 (46) 0 0
Syria – 22 Feb 1995 0/15 (33) 0/10 (10) 10/15 (42)
Tajikistan (48) – 26 Aug 1983 0 0 0
Thailand – 4 April 2000 10 10/15 (34) 5/10/15 (35)
Ukraine – 1 Jan 2014 5/15 (36) 2 5/10 (37)
United Arab Emirates – 1 Jan 2014 0 0 0
United Kingdom – 1 Nov 1974 0/15 (38) 10 0/5 (18)
United States – 31 Dec 1985 5/15 (39) 0/10 (17) 0
Uzbekistan (48) – 26 Aug 1983 0 0 0

Cyprus Double Tax Treaty Network 

Notes:


  1. Cyprus does not levy a WHT on dividends, interests, and royalties paid to non-residents of Cyprus except in the case of royalties earned on rights used within Cyprus, which are subject to WHT of 10% (5% in the case of cinematographic films)..
  2. The rate of 5% if a dividend is paid by a company in which the beneficial owner has invested less than EUR 150.000.
  3. A rate of 5% if the investment is not less than EUR200.000 in the share capital of the company paying the dividend. If such investment is less than EUR 200000, dividends are subject to 15% WHT which is reduced to 10% if the recipient company controls 25% or more of the paying company
  4. A rate of 15% applies if received by a company holding less than 25% of the share capital of the paying company and in all cases if received by an individual.
  5. No WHT if paid to the government/Central Bank/ Public Authority of the other state
  6. No WHT for interest on deposits with banking institutions.
  7. Serbia, Montenegro and Bosnia apply the Yugoslavia/Cyprus treaty.
  8. The 5% rate applies to companies holding directly at least 25% of the share capital of the company paying the dividend. In all other cases the WHT is 10%.
  9. The treaty rates do not apply if the payment is made to a Cyprus entity by a resident of Bulgaria owning directly or indirectly at least 25% of the share capital of the Cyprus entity and the Cyprus entity pays tax in Cyprus at a tax rate lower than the usual tax rate.
  10. Nil if paid to a government/Central Bank/ Public Authority or for export guarantee.
  11. Nil on literary, dramatic, musical, or artistic work (but not including royalties in respect of motion picture films and works on film or videotape for use in connection with television).
  12. Nil applies if received by a company (excluding partnership) which holds directly at least 10% of the share capital of the paying company for an uninterrupted period of no less than one year. 5% applies in all other cases.
  13. 10% for patent, trademark, design or model, plan, secret formula or process, computer software or industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience.
  14. A rate of 15% if received by a company controlling less than 10% of the share capital of the paying company or the duration of any holding is less than one uninterrupted year. A rate of 15% also applies if received by an individual.
  15. A rate of 15% applies if received by a company controlling less than 10% of the voting power in the paying company and in all cases if received by an individual.
  16. A rate of 15% if received by a company (partnership is excluded) holding less than 10% of the capital of the paying company and in all cases if received by an individual.
  17. Nil if paid to a government, bank, or financial institution.
  18. A rate of 5% on royalties for cinematographic films including films and video tapes for television.
  19. A rate of 15% if received by a company holding less than 10% of the capital of the paying company and in all cases if received by an individual.
  20. A rate of 5% on cinematographic film royalties (other than films shown on television).
  21. A rate of 15% if received by a company holding less than 10% of the shares of the paying company and in all cases if received by an individual.
  22. A rate of 10% for payments of a technical, managerial, or consulting nature.
  23. A rate of 5% if received by a company (other than partnership) holding less than 10% of the capital of the company paying the dividend and in all cases if received by an individual.
  24. Nil rate applies if the recipient company (partnership is excluded) holds directly 10% of the share capital of the paying company for an uninterrupted period of at least 2 years. 5% in all other cases.
  25. A rate of 5% applies if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends. A rate of 10% in all other cases.
  26. 5% 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.
  27. A rate of 10% on dividend if paid by a company in which the beneficial owner has invested less than EUR100.000 in the share capital of the company paying the dividend.
  28. A rate of 7% if paid to a bank or financial institution.
  29. A rate of 5% if received by a company holding less than 10% of the capital of the paying company and in all cases if received by an individual or a company not limited at least partly by shares.
  30. The treaty with Spain is effective January 1, 2015 (with the exception of withholding taxes which have been effective May 28, 2014). This is the first double tax treaty between the two countries.
  31. The treaty with Lithuania is effective from January 1, 2015. This is the first double tax treaty between the two countries.
  32. The treaty with Norway is effective from January 1, 2015. This replaces the previous treaty effective between the two countries.
  33. A rate of 15% if received by a company holding less than 25% of the share capital of the paying company and in all cases if received by an individual or a company not limited at least partly by shares.
  34. A rate of 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.
  35. A rate of 5% 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, trade-marks, designs or models, plans, secret formulas, or processes.
  36. A rate of 15% if a dividend is paid by a company in which the beneficial owner holds less than 20% of the share capital of the paying company and the beneficial owner has invested less than EUR100.000.
  37. A 5% WHT will be levied on payment of royalties in respect of any copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience. 10% WHT will be levied in all other cases.
  38. A rate of 15% applies to individual shareholders regardless of their percentage of shareholding. Companies controlling less than 10% of the voting shares are also entitled to a rate of 15%. Companies controlling at least 10% of the voting shares are entitled to nil WHT.
  39. A rate of 15% if received by a company controlling less than 10% of the voting power of the paying company and in all cases if received by an individual. If a company controls at least 10% of the voting power of the paying company in order to benefit from the WHT rate of 5% other conditions relating to the income of the paying company need to be satisfied, otherwise a WHT rate of 15%.
  40. Nil rate applies if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends or if the beneficial owner of the shares is the Government of Cyprus or Norway. A rate of 15% in all other cases.
  41. The Cyprus – Czechoslovakia treaty applies with the Slovak Republic.
  42. 10% rate applies on payment of royalties of any copyright of literary, artistic or scientific work including cinematograph films, and films or tapes for television or radio broadcasting. A rate of 15% applies on payments of royalties of any patent, trade mark, design or model, plan, secret formula or process, or any industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience.
  43. The new double tax agreement between Cyprus and Iceland, which was signed on November 13 2014, entered into force on December 22 2014. Its provisions apply to taxes withheld at source that are paid or credited on or after January 1 2015 and for other taxes in respect of taxable years beginning after that date.
  44. Withholding tax on dividends paid by a company resident in Iceland to a company (but not a partnership) resident in Cyprus is limited to 5% of the gross dividend, provided that the recipient is the beneficial owner of at least 10% of the shares in the company paying the dividend. Otherwise, the maximum rate of withholding tax is 10%.
  45. On July 25 2014 Switzerland and Cyprus signed a new agreement for the avoidance of double taxation. It is the first double tax agreement between the two countries and will contribute to the development of bilateral economic relations. The agreement will come into force once it has been ratified by both countries.
  46. The double tax agreement exempts dividends paid by a company resident in one contracting state to a resident of the other from withholding taxes in the contracting state from which they originate, as long as the beneficial owner of the dividend is a company (but not a partnership) resident in the second contracting state that has held at least 10% of the capital of the company paying the dividend for at least a year without interruption. Dividends paid to pension funds or to government bodies (including a central bank) in the other contracting state are also exempt. Otherwise, the dividend may be taxed at up to 15%.
  47. This is the first double tax treaty between Cyprus and Guernsey. The treaty was signed on July 29, 2014. Cyprus ratified the treaty on August 14, 2014. The treaty has not yet entered into force.
  48. The treaty between Cyprus and the Union of Soviet Socialist Republics is still in force.
Cyprus Double Tax Treaty Network

Review our Updated Cyprus Double Tax Treaty Network

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