Double Tax Treaties

Received in Cyprus

 

Dividends

Interest

Royalties

 

%

%

%

Armenia

0(32)

5(33)

5

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

Czech Republic

0(30)

0

10

Denmark

0(34)

0

0

Egypt

15

15

10

Estonia

0

0

0

Finland

5(37)

0

0

France

10(2)

10(9)

0(26)

Germany (31)

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  (31)

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

Moldova

5(19)

5

5

Montenegro (28)

10

10

10

Norway

5(3)

0

0

Poland

10

10(8)

5

Portugal

0(36)

5(8)

5

Qatar

0

0

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

5

5(33)

5

South Africa

0

0

0

Spain(31)

0(35)

0

0

Sweden

5(1)

10(8)

0

Syria

0(1)

10(8)

15(13)

Tajikistan (27)

0

0

0

Thailand

10

15(17)

5(18)

Ukraine

0

0

0

United Arab Emirates (35)

0

0

0

United Kingdom

0(24)

10

0(26)

USA

15(5)

10(10)

0

Uzbekistan

0

0

0

 

Paid from Cyprus*

 

Dividends

Interest

Royalties

 

%

%

%

Non treaty countries

0

0

0**

Armenia

0(32)

5(33)

5

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

0(30)

0

10

Denmark

0(34)

0

0

Egypt

15

15

10

Estonia

0

0

0

Finland

5(37)

0

0

France

10(2)

10(9)

0(26)

Germany (31)

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  (31)

10

10(8)

5(14)

Kyrgyzstan (27)

0

0

0

Lebanon

5

5(16)

0

Malta

15

10(8)

10

Mauritius

0

0

0

Moldova

5(19)

5

5

Montenegro (28)

10

10

10

Norway

0

0

0

Poland

10

10(8)

5

Portway

10

10

10

Qatar

0

0

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

5

5(33)

5

South Africa

0

0

0

Spain(31)

0(35)

0

0

Sweden

5(1)

10(8)

0

Syria

0(1)

10(8)

15(13)

Tajikistan (27)

0

0

0

Thailand

10

15(17)

5(18)

Ukraine (27)*

0

0

0

United Arab Emirates  (35)

0

0

0

United Kingdom

0

10

0(26)

USA

0

10(10)

0

Uzbekistan (27)

0

0

0

 

 

 

*.    Payments of dividends and interest to non residents are exempt from withholding tax in Cyprus according to the local 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 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. (The Protocol to the existing treaty, which as of today – February 2012 - has yet to become effective, provides for a change in the amount invested from $100,000 to €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 organization.

  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 fi lm 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 by 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. This rate is applicable if received by a company owning directly at least 25% of the capital. In all other cases the withholding tax is 10%.

  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 and 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.

  30. Nil 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 where such holding is being possessed for an uninterrupted period of no less than one year. 5% in all other cases.

  31. The new treaty which provides for changes in the above rates has been published in the Government Gazette but has not come into force until today (February 2012).

  32. 5% if the beneficial owner has invested in the capital of the company less than the equivalent of €150.000 at the time of the investment.

  33. Nil if paid to the Government or to the local authority, or to the Central Bank.

  34. Nil 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, where such holding is being possessed for an uninterrupted period of no less than 12 months.

    Nil if the beneficial owner is the other Contracting State or the Central Bank of that other State, or any national agency or any other agency (including a financial institution) owned or controlled by the Government of that other State.

    Nil if the beneficial owner is a pension fund or other similar institution providing pension schemes in which individuals may participate in order to secure retirement benefits, where such pension fund or other similar institution is established, recognized for tax purposes and controlled in accordance with the laws of that other State. 15% in all other.

  35. The treaty has been published in the Government Gazette but has not come into force until today (February 2012).

  36. NIL 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, where such holding is being possessed for an uninterrupted period of no less than 24 months. 5% in all other cases.

  37. 5% if the dividend is received by a company (other than a partnership) which controls directly at least 10% of the voting power in the company paying the dividends. 15% in all other cases.