///Double Tax Treaties of Cyprus

Double Tax Treaties of Cyprus

Cyprus differs from most other offshore jurisdictions, in that it offers a big number of double tax treaties

Double Tax Treaties of Cyprus 2018-05-02T08:42:14+00:00

Cyprus differs from most other offshore jurisdictions, in that it offers a big number of double tax treaties (50 in total), for the avoidance of double taxation. In general most of the conventions provide reduced rates of withholding taxes on dividends, interest and royalties paid out of the contracting state, or the avoidance of double taxation in the case where a resident in one of the contracting states derives income from the other contracting state. This is one of the key areas which makes Cyprus as an International and Offshore Business Centre unique and respectable.

Cyprus has concluded an impressive number of Double Tax Treaties, something which tax heavens lack in almost all cases.

The following table summarizes the withholding tax rates applicable for dividends, interest and royalties paid from the countries shown to residents of Cyprus (for numbers in parenthesis (n) refer to the notes below):

Country Paid from countries Shown to residents of Cyprus
Dividends Interest Royalties
Armenia 0/5% (35) 5% 5
Austria 10 0 0
Azerbaijan 0 0 0
Barbados 0 0 0
Belarus 5/10/15% (26) 5 5
Belgium 10/15 (25) 0/10(4) 0
Bosnia (43) 10% 10% 10%
Bulgaria 5/10(19) 0/7%(1),(2) 10(2)
Canada 15 0/15(36) 0/10(37)
China 10 10 10
Czech Republic 0/5(20) 0 0/10(38)
Denmark 0/15%(1),(30) 0 0
Egypt 15 15 10
Estonia 0 0 0
Ethiopia 5 5 5
France 10/15(7) 0/10(6) 0/5(8)
Finland 5/15(39) 0 0
Georgia 0 0 0
Germany 5/15(10) 0 0
Greece 25 10 0/5(11)
Hungary 5/15(25) 0/10(1) 0
Iceland 5/10%(5) 0 5
India 10(40) 0/10(1) 10(9)
Iran (47) 5/10%(32) 5% 6%
Ireland 0 0 0/5(11)
Italy 15 10 0
Jersey(47) 0 0 0
Kindom of Bahrain 0 0 0
Kuwait 0 0 5
Kyrgyzstan 0 0 0
Latvia 0/10%(44) 0/10%(44) 0/10%(45)
Lebanon 5 5 0
Lithuania 0/5%(24) 0% 5%
Luxemburg Not yet in force, only protocol/treaty/note was signed
Malta 0 10 10
Mauritius 0 0 0
Moldova 5/10(33) 5 5
Montenegro 10 10 10
Norway 0/15%(41) 0 0
Poland 0/5%(42) 0/5%(1) 5
Portugal 10 10 10
Qatar 0 0 5
Romania 10% 0/10%(1) 0/5%(48)
Russia 5/10%(18) 0 0
San Marino 0 0 0
Serbia & Montenegro 10 10 10
Seychelles 0 0 5
Singapore 0 0/7/10(27) 10
Slovakia (49) 0/5/10(50) 0/10(1) 0/5(3)
Slovenia 5 5 5
South Africa 5/10 (45) 0 0
Spain 0/5%(31) 0 0
Sweden 5/15(12) 0/10(1) 0
Switzerland 0/15%(46) 0 0
Syria 0/15(13) 0/10(36) 10/15(21)
Thailand 10 10/15(22) 5/10/15(23)
The State of Guernsey 0 0 0
Ukraine 5/15(16) 2 5/10(17)
United Arab Emirates 0 0 0
United Kingdom 0/15(14) 10 0/5(8)
United States of America 5/15(15) 0/10(34) 0
Uzbekistan 0 0 0

Notes to the table above:

  1. Nil if paid to the Government/ Central Bank/ Public Authority of the other State.
  2. 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.
  3. A rate of 5% 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.
  4. Nil if paid to the Government Central Bank/ Public authority. Nil on deposits with bank institutions of the other State.
  5. A rate of 5% applies if received by company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividend. 10% in all other cases.
  6. Nil if paid to the Government bank or financial institution.
  7. A rate of 15% applies if received by a company holding less than 10% of the capital and in all cases if received by an individual.
  8. A rate of 5% applies on film and TV royalties.
  9. A rate of 10% applies to technical managerial or consulting nature. Prior to 1 April 2017, a rate of 15% applies on royalties.
  10. A rate of 15% applies 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.
  11. A rate of 5% applies on film royalties, other than films shown on television.
  12. A rate of 15% applies if received by a company holding less than 25% of the capital and in all cases received by an individual.
  13. 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 or a company not limited at least partly by shares.
  14. 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.
  15. A rate of 15% applies 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 WHT rate of 5% other conditions relating to the income of the paying company need to be satisfied, otherwise a WHT rate of 15%.
  16. 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 100.000 euro.
  17. A rate of 5% applies WHT will be levied on payment of royalties in respect of any copyright of scientific work, any patent, trademark, secret formula, process or information concerning industrial, commercial or scientific experience. 10% WHT will be levied in all other cases.
  18. A rate of 10% applies if received by a company that has directly invested in the capital of the paying company less than the equivalent of 100.000 Euro.
  19. A rate of 5% applies if received by a company holding directly of least 25% of the share capital. Otherwise 10%.
  20. 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.
  21. A rate of 10% applies on literary, artistic or scientific work including cinematograph films and films of tapes for television or radio broadcasting. A rate of 15% applies on payments of royalties of any patent, trademark, design or model, plan, secret formula or process, or any industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience.
  22. A rate of 10% applies if paid to financial institution (including an insurance company) or if paid in connection with the sale on credit of any industrial, commercial or scientific equipment, or if paid in connection with the sale on credit of any merchandise by one enterprise to another enterprise.
  23. A rate of 5% applies to copyright royalties paid in respect of literary, dramatic, musical, artistic or scientific work, including software, and film and broadcasting royalties. The 10% rate applies to royalties paid in respect of industrial, commercial and scientific equipment. The rate is 15% for patent and trademark designs or models, plans, secret formulas or process.
  24. A rate of 5% applies 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.
  25. A rate of 15% applies if received by a company holding directly less than 25% of the share capital and in all cases if received by an individual.
  26. A rate of 5% applies if received by a company that invested in share capital not less than €200.000. 10% if paid to a person holding at least 25% of the capital. In all other cases 15%.
  27. A rate of 7% applies if received by a bank or similar financial institution.
  28. Nil applies if the payer is a company that is a resident in Latvia and the beneficial owner of the income is a company (other than partnership) that is a resident in Cyprus. 10% rate applies for all other cases (except for certain governmental interest).
  29. Nil applies if the payer is a company that is a resident in Latvia and the beneficial owner of the income is a company (other than partnership) that is a resident in Cyprus. 5% rate applies for all other cases.
  30. 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.
  31. 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.
  32. A rate of 5% applies if the beneficial owner of the dividends holds directly at least 25% of the capital of the company paying the dividends.
  33. This rate applies if received by a company controlling directly at least 25% of the capital. In all other cases 10% rate applies.
  34. Nil if paid to a government, bank or financial institution.
  35. The rate of 5% if a dividend is paid by a company in which the beneficial owner has invested less than 150.000 euro.
  36. Nil if paid to a government/ Central bank/ Public Authority or for export guarantees.
  37. Nil on literary, dramatic, musical or artistic work (but not including royalties in respect of motion picture films & works on films or videotape for use in connection with television).
  38. 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.
  39. 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.
  40. Prior to 1 April 2017, the applicable rate is 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.
  41. 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.
  42. 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.
  43. Serbia, Montenegro and Bosnia apply the Yugoslavia/ Cyprus treaty.
  44. The Cyprus – Czechoslovakia treaty applies with the Slovak Republic.
  45. A protocol to the treaty entered into force on 18 September 2015 but may apply retrospectively. 5% rate applies if the beneficial owner is a company which holds at least 10% of the capital of the company paying the dividend. 10% in all other cases.
  46. A rate of 0% appliers if the beneficial owner of the dividend is (i) a company (the term does not include  partnerships) whose  capital is wholly or partly divided into shares holding directly at least 10% of the capital of the company paying the dividend for an uninterrupted period of at least one year. (the time period criterion may be satisfied post the date of the dividend payment), or (ii) a pension fund or other similar  institution recognized as such for tax purposes, or (iii) the Government, a political subdivision, local authority or central bank of one of the two contracting states.
  47. The treaty is effective as from 1 January 2018
  48. A rate of 5% applies for parents, 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.
  49. The Cyprus – Czechoslovakia treaty applies with the Slovak Republic.

A rate of 5% applies if received by a company holding less than 10% of the capital of the company paying the dividend and in all cases if received by an individual or a company not limited at least partly by shares.