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Cyprus Tax – Cyprus double tax treaties

 

CYPRUS DOUBLE TAX TREATIES

The following table is a summary of the applicable withholding tax rates for the income between countries having a double taxation treaty with Cyprus. The tax rates below are valid under certain conditions which are determined by the provisions of each agreement.

TABLE OF CYPRUS WITHHOLDING TAX RATES (CYPRUS DOUBLE TAX TREATIES TABLE)

 

Received in Cyprus

Paid from Cyprus(1)

Treaty  country                                                                

Divden

Interest

Royalt

Dividen

Interest

Royalt

Armenia

0(24)

5

5

0(24)

5

5

Austria

10

0

0

10

0

0

Azerbaijan (36)

0

0

0

0

0

0

Bahrain

0

0

0

0

0

0

Bailiwick of Guernsey

0

0

0

0

0

0

Barbados (31)

0

0

0

0

0

0

Belarus

    5(14)

5

5

 5(14)

5

5

Belgium

    10(5)

 10(4,39)

0

 10(5)

10

0

Bulgaria

    5(20)

 7(4,23)

 10(23)

 5(20)

  7(4)

10

Canada

15

   15(3)

 10(12)

15

  15(3)

 10(12)

China

10

10

10

10

10

10

CzechRepublic

0(27)

0

0(28)

0(27)

0

0(28)

Denmark (29)

   0(40)

   0

0

0(40)

   0

0

Egypt

15

15

10

15

15

10

Estonia

0

0

0

0

0

0

Ethiopia (43)

5

5(4)

5

5

5(4)

5

France

   10(6)

   10(7)

   0(2)

 10(6)

  10(7)

  0(2)

Finland

   5(33)

0

0

 5(33)

0

0

Georgia

0

0

0

0

0

0

Germany

   5(6)

0

0

   5(6)

0

    0
Greece

   25(8)

10

   0(9)

25

10

   0(9)

Hungary

   5(5)

   10(4)

0

0

  10(4)

0

Iceland

    5(34)

0

5

5(34)

0

5

India (47)

   10(6)

  10(7)

  15(1)

 10(6)

  10(7)

15(11)

Iran (43)

5(44)

5(4)

6

5(44)

5(4)

6

Ireland

0

0

   0(9)

0

0

   0(9)

Italy

15

10

0

0

10

0

Jersey (43)

0

0

0

0

0

0

Kuwait

0

  0

  5

0

  0

  5

Kyrgyzstan (36)

0

0

0

0

0

0

Latvia

0(47)

0(48)

0(49)

0(47)

0(48)

0(49)

Lebanon

5

  5(15)

0

5

  5(15)

0

Lithuania

    0(37)

0

5

 0(37)

0

5

Malta

0

10(7)

10

15

10(4)

10

Mauritius

0

0

0

0

0

0

Norway

    0(16)

0

0

0

0

0

Poland

   10(41)

   5(4)

5

 0(38)

   5(4)

5

Portugal

10

10

10

10

10

10

Qatar

0

0

5

0

0

5

Romania

10

  10(4)

  5(13)

10

  10(4)

  5(13)

Russia

   5(17)

0

0

 5(17)

0

0

San Marino

0

0

0

0

0

0

Serbia & Montenegro(25)

10

10

10

10

10

10

Seychelles

0

0

5

0

0

5

Singapore

0

10(18)

10

0

10(18)

10

Slovakia (30)

10

  10(4)

  5(13)

10

  10(4)

  5(13)

Slovenia

5

5

5

5

5

5

South Africa

0

0

0

0

0

0

Spain

   0(35)

0

0

0(35)

0

0

Sweden

   5(5)

  10(4)

0

  5(5)

  10(4)

0

Swiss Confederation

0(40)

0

0

0(40)

0

0

Syria

   0(5)

  10(4)

15(19)

  0(5)

  10(4)

15(19)

Tajikistan(36)

0

0

0

0

0

0

Thailand

10

10(21)

  5(22)

10

10(21)

  5(22)

Ukraine(46)

5(32)

2

5(42)

5(32)

2

5

United Arab Emirates

0

0

0

0

0

0

United Kingdom

  15(10)

10

  0(2)

0

10

0(2)

United States of America

   15(26)

  10(7)

0

0

  10(7)

0

Uzbekistan(36)

0

0

0

0

0

0

Cyprus double tax treaties notes:

1. Dividends and interest paid to non-residents of Cyprus, as well as royalties payable abroad and granted for use outside Cyprus are exempt from any  Cyprus withholding tax.

2. 5% applies only on television and film rights.

3. 0% applies if it is paid to a Government or for export guarantee.

4. 0% applies if it is paid to the Government of the contracting state.

5. 15% applies if it is received by a company that controls less than 25% of the voting rights and in all cases if received by individual.

6. 15% applies if it is received by a company that controls less than 10% of the voting rights and in all cases if received by individual.

7. 0% applies if it is paid to a Government, a financial institution or a bank of the contracting state.

8. The double tax treaty between Cyprus and Greece provides 25% withholding tax but according to the legislation of Greece 10% tax is withheld as from 1/1/2009.

9. 5% applies only on film rights.

10. The double tax treaty between Cyprus and United Kingdom provides 15% withholding tax no tax is withheld on dividends according to the legislation of the United Kingdom. Companies controlling at least 10% of the voting rights are not entitled to withholding tax.

11. 10% applies for payments of a technical, administrative or advisory nature.

12. 0% applies on theatrical, musical, literary or any other artistic work.

13. 0% applies for patents, production processes or any royalties arising from scientific research.

14. 15% applies in cases of investments which are less than €200.000. The withholding tax  can be reduced to 10% if the investment is over 25% of the company’s share capital.

15. 0% applies if is paid to the Government of the contracting state or to any other institution, local authority and any bank which is owned entirely by the state.

16. 0% applies if it is received by a company (other than a partnership) holding at least 10% of the share capital of the company issuing the dividend or if it is paid to the Government of any of the two contracting states. 15% applies in all other cases.

17. 10% applies when the dividends are received from a company which invested less than €100.000.

18. 7% applies if it is paid to a bank or a relevant financial institution.

19. 10% applies on artistic, scientific and literary work.

20. 10 % applies if it is received by a company holding less than 25% of the share capital of the company issuing the dividend.

21. 10% applies on interest paid to a financial institution or on interest paid in connection with commercial, industrial or even scientific equipment

22. 10% applies on royalties in connection with commercial, industrial or even scientific equipment increases to 15% for patents, production processes or any other royalties arising from scientific research.

23. The rates apply when the payment it is made to a Cyprus Company by a Bulgarian resident which holds directly or indirectly less than 25% of a Cyprus company’s share capital.

24. A rate of 5% if a dividend is paid by a company in which the beneficial owner has invested less than €150.000.

25. The provisions of the double tax treaty between the Republic of Cyprus and the former Socialist Federal Republic of Yugoslavia still applies. Bosnia also applies this provision.

26. 5% applies if it is received by a company which controls at least 10% of the voting rights.

27. Applies if it is received by a company owning directly 10% of the shares for an uninterrupted period of one year. In all other cases 5% applies.

28.10% applies for the following: patent, trade mark, design or model, plan, secret formula or process, computer software or industrial, commercial or scientific equipment, or for    information concerning commercial, industrial or scientific experience.

29. Under its provisions no withholding tax will apply, assuming that the company holds at least 10% of share capital and for a minimum shareholding period of 12 months, otherwise a 15% withholding applies.

30. The treaty between the Republic of Cyprus and the Czechoslovak Socialist Republic still applies.

31. The treaty is effective from 1st January 2018.

32.15% applies if the investment is less than €100.000 and lower of 20% of the company’s share capital.

33. 5% applies if the recipient is a company that owns at least 10 % of the company distributing the dividends, with voting rights in the company distributing the dividends. In all other cases a 15% applies.

34.  5% applies if the recipient is a company that owns at least 10 % of the company distributing the dividends. In all other cases a 10% applies.

35. 0% applies if the dividend is received by a company holding at least 10% of the issued share capital. 5% applies in all other cases.

36. The treaty between the Republic of Cyprus and the United Soviet Socialist Republic still applies.

37. 0% applies if the beneficial owner is a company which holds directly at least 10% on the capital of the company paying the  dividends. 5% applies in all other cases.

38. 0% applies if the beneficial owner is a company which holds directly at least 10% on the capital of the company paying the  dividends, where such holding is being possessed for an interrupted period of 24 months. 5% applies in all other cases.

39. Nil withholding tax is applied on interests derived from deposits in financial institutions.

40. 0% applies if it is received by a company (other than a partnership) holding at least 10% of the share capital of the company issuing the dividend for a minimum shareholding period of 12 months, or if it is paid to the Government of any of the two contracting states, pension fund or any similar institution. 15% applies in all other cases.

41. The treaty is effective from 18 September 2015 but may apply retrospectively. 5% applies if the recipient is a company that owns at least 10 % of the company distributing the dividends. In all other cases a 10% applies.

42. 5% applies for royalties in respect of copyrights of scientific work, patent, trade mark, secret formula, production process or information relating to industrial, commercial or scientific experience. 10% applies in all other cases.

43. The treaty has been published in the Gazette but has not come into force until the time of publication of this guide.

44. 5% applies if the recipient is a company that owns at least 25 % of the company distributing the dividends. In all other cases a 10% applies.

45. It was formed a new treaty, which is expected to be effective not earlier than 1/1/2019.

46. It was formed a new treaty, which is not signed yet.

47. 0% applies if it is received by a company (other than a partnership). 10% applies in all other cases.

48. 0% applies if it is received by a company (other than a partnership) or by the government of any of the two contracting states. 10% applies in all other cases.

49. 0% applies if it is received by a company (other than a partnership). 5% applies in all other cases.

50. Other than the Double Tax Agreements which are presently in force, the conclusion of various other Agreements is pending. These Agreements are currently under negotiation.

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Last update: April 2017

The authors expressly disclaim all and any liability and responsibility to any person, entity or corporation who acts or fails to act as a consequence of any reliance upon the whole or any part of the contents of this publication.

Accordingly no person, entity or corporation should act or rely upon any matter or information as contained or implied within this publication without first obtaining advice from an appropriately qualified professional person or firm of advisors, and ensuring that such advice specifically relates to their particular circumstances.

PKF Cyprus firms are member firms of the PKF International Limited network of legally independent firms and do not accept any responsibility or liability for the actions or inactions on the part of any other individual member firm or firms.

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