Cyprus Double Tax Treaties

Dividends, Interest and Royalties received in Cyprus:

 

Dividends

(%)

Interest

(%)

Royalties

(%)

Armenia – Cyprus double tax treaty

0 (32)

5 (33)

5

Austria (31) – Cyprus double tax treaty

10

0

0

Belarus – Cyprus double tax treaty

5 (4)

5

5

Belgium – Cyprus double tax treaty

10 (1)

10 (16)

0

Bulgaria – Cyprus double tax treaty

5 (19)

7 (25)

10 (20)

Canada – Cyprus double tax treaty

15

15 (7)

10 (11)

China – Cyprus double tax treaty

10

10

10

Czech Republic – Cyprus double tax treaty

0 (30)

0

10

Denmark – Cyprus double tax treaty

0 (34)

0

0

Egypt – Cyprus double tax treaty

15

15

10

Estonia – Cyprus double tax treaty

0

0

0

Finland – Cyprus double tax treaty

5 (37)

0

0

France – Cyprus double tax treaty

10 (2)

10 (9)

0 (26)

Germany – Cyprus double tax treaty

5 (2)

0

0

Greece – Cyprus double tax treaty

25

10

0 (12)

Hungary – Cyprus double tax treaty

5 (1)

10 (8)

0

India – Cyprus double tax treaty

10 (2)

10 (8)

15 (15)

Ireland – Cyprus double tax treaty

0

0

0 (12)

Italy – Cyprus double tax treaty

15

10

0

Kuwait – Cyprus double tax treaty

10

10 (8)

5 (14)

Kyrgyzstan (27) – Cyprus double tax treaty

0

0

0

Lebanon – Cyprus double tax treaty

5

5 (16)

0

Malta – Cyprus double tax treaty

0 (22)

10 (8)

10

Mauritius – Cyprus double tax treaty

0

0

0

Moldova – Cyprus double tax treaty

5 (19)

5

5

Montenegro (28) – Cyprus double tax treaty

10

10

10

Norway – Cyprus double tax treaty

5 (3)

0

0

Poland – Cyprus double tax treaty

0 (36)

5 (8)

5

Portugal – Cyprus double tax treaty

10

10

10

Qatar – Cyprus double tax treaty

0

0

5

Romania – Cyprus double tax treaty

10

10 (8)

5 (14)

Russia – Cyprus double tax treaty

5 (6)

0

0

San Marino – Cyprus double tax treaty

0

0

0

Serbia (28) – Cyprus double tax treaty

10

10

10

Seychelles – Cyprus double tax treaty

0

0

5

Singapore – Cyprus double tax treaty

0

10 (23)

10

Slovakia (29) – Cyprus double tax treaty

10

10 (8)

5 (14)

Slovenia – Cyprus double tax treaty

5

5 (33)

5

South Africa– Cyprus double tax treaty

0

0

0

Spain (31) – Cyprus double tax treaty

0 (35)

0

0

Sweden – Cyprus double tax treaty

5 (1)

10 (8)

0

Syria – Cyprus double tax treaty

0 (1)

10 (8)

15 (13)

Tajikistan (27) – Cyprus double tax treaty

0

0

0

Thailand – Cyprus double tax treaty

10

15 (17)

5 (18)

Ukraine – Cyprus double tax treaty

5 (21)

2

5

United Arab Emirates (35) – Cyprus treaty

0

0

0

United Kingdom – Cyprus double tax treaty

0 (24)

10

0 (26)

USA – Cyprus double tax treaty

5 (5)

10 (10)

0

Uzbekistan (27) – Cyprus double tax treaty

0

0

0

 

 

Dividends, Interest and Royalties paid from Cyprus:

Please note that Cyprus domestic law states that payments of dividends and interest to non-residents are exempt from withholding tax in Cyprus - therefore the table below will not apply. Similarly, royalties granted for use outside of Cyprus are also exempt form withholding tax in Cyprus.

 

 

Dividends

(%)

Interest

(%)

Royalties

(%)

Non-treaty countries (0) – Cyprus double tax treaty

0

0

0

Armenia – Cyprus double tax treaty

0 (32)

5 (33)

5

Austria (31) – Cyprus double tax treaty

10

0

0

Belarus – Cyprus double tax treaty

5 (4)

5

5

Belgium – Cyprus double tax treaty

10 (1)

10

0

Bulgaria – Cyprus double tax treaty

5 (19)

7 (25)

10

Canada – Cyprus double tax treaty

15

15 (7)

10 (11)

China – Cyprus double tax treaty

10

10

10

Czech Republic – Cyprus double tax treaty

0 (30)

0

10

Denmark – Cyprus double tax treaty

0 (34)

0

0

Egypt – Cyprus double tax treaty

15

15

10

Estonia – Cyprus double tax treaty

0

0

0

Finland – Cyprus double tax treaty

5 (37)

0

0

France – Cyprus double tax treaty

10 (2)

10 (9)

0 (26)

Germany – Cyprus double tax treaty

5 (2)

0

0

Greece – Cyprus double tax treaty

25

10

0 (12)

Hungary – Cyprus double tax treaty

0

10 (8)

0

India – Cyprus double tax treaty

10 (2)

10 (8)

15 (15)

Ireland – Cyprus double tax treaty

0

0

0 (12)

Italy – Cyprus double tax treaty

0

10

0

Kuwait – Cyprus double tax treaty

10

10 (8)

5 (14)

Kyrgyzstan (27) – Cyprus double tax treaty

0

0

0

Lebanon – Cyprus double tax treaty

5

5 (16)

0

Malta – Cyprus double tax treaty

15

10 (8)

10

Mauritius – Cyprus double tax treaty

0

0

0

Moldova – Cyprus double tax treaty

5 (19)

5

5

Montenegro (28) – Cyprus double tax treaty

10

10

10

Norway – Cyprus double tax treaty

0

0

0

Poland – Cyprus double tax treaty

0 (36)

5 (8)

5

Portugal – Cyprus double tax treaty

10

10

10

Qatar – Cyprus double tax treaty

0

0

5

Romania – Cyprus double tax treaty

10

10 (8)

5 (14)

Russia – Cyprus double tax treaty

5 (6)

0

0

San Marino – Cyprus double tax treaty

0

0

0

Serbia (28) – Cyprus double tax treaty

10

10

10

Seychelles – Cyprus double tax treaty

0

0

5

Singapore – Cyprus double tax treaty

0

10 (23)

10

Slovakia (29) – Cyprus double tax treaty

10

10 (8)

5 (14)

Slovenia – Cyprus double tax treaty

5

5 (33)

5

South Africa – Cyprus double tax treaty

0

0

0

Spain (31) – Cyprus double tax treaty

0 (35)

0

0

Sweden – Cyprus double tax treaty

5 (1)

10 (8)

0

Syria – Cyprus double tax treaty

0 (1)

10 (8)

15 (13)

Tajikistan (27) – Cyprus double tax treaty

0

0

0

Thailand – Cyprus double tax treaty

10

15 (17)

5 (18)

Ukraine – Cyprus double tax treaty

5 (21)

2

5

United Arab Emirates (35) – Cyprus tax treaty

0

0

0

United Kingdom – Cyprus double tax treaty

0

10

0 (26)

USA – Cyprus double tax treaty

0

10 (10)

0

Uzbekistan (27) – Cyprus double tax treaty

0

0

0

 

Notes:

0. 10% if the royalties granted are for use within the Republic and 5% if these are on film and TV rights.

1. If these are received by a company controlling less than 25% of the voting power then the rate becomes 15% .

2. If these are received by a company controlling less than 10% of the voting power then the rate becomes 15% .

3. Zero if paid to a company controlling more than 50% of the voting power.

4. Valid only if the amount invested by the beneficial owner is over €200.000. If not, 10% is imposed if received by a holder of equal or more than 25% of the share capital of the paying company and if less the rate becomes 15%.

5. Only if received by a company controlling at least 10% of the voting power, otherwise, the rate becomes 15%.

6. Only if the company receiving it invested more than €100,000, otherwise the applicable rate becomes 10%.

7. Zero if paid to the Government or for export guarantee.

8. Zero if paid to the Government of the other State or to a financial institution.

9. Zero in some cases – please check the treaty for details.

10. Zero if paid to the Government of the other State, to a bank or a financial institution or in respect to debt obligations under certain circumstances.

11. Zero on literary, dramatic, musical or artistic work. This does not apply to films used for television programs.

12. 5% on film royalties apart from those used for TV.

13. 10% on literary, musical, artistic work, films and TV royalties.

14. Zero on literary, artistic or scientific work.

15. The rate is restricted to Cyprus domestic legislation rate of 10% which also applies to payment of technical, management and consultancy fees.

16. Zero if paid to the Government of the other State, a local authority, the National Bank, institutions belonging to the State or if paid 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 and scientific and in some other cases.

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. The rate becomes 5% if the dividend is paid to a company owning directly at least 25% of the capital and 10% in all other cases.

20. This rate does not apply if 25% or more of the capital of the Cyprus resident is owned directly or indirectly by a Bulgarian resident paying the royalties and the Cyprus company pays less than the normal rate of tax.

21. 5% is applicable if the dividend is received by a company owning 20% or more of the capital of the paying company or if it has invested in the acquisition of shares of the paying company (or has invested directly in the paying company) at least €100.000. The rate in all other cases is 15%.

22. The treaty states that the tax on the gross amount of the dividends cannot be more than the tax on the profits out of which the dividends are paid.

23. The rate becomes 7% if paid to a financial institution and zero if paid to the government.

24. The treaty actually states 15% withholding tax, however, the domestic low which prevails provides for 0%.

25. Zero if paid to or is guaranteed by the Government, statutory body, the Central Bank.

26. 5% on film royalties.

27. The applicable treaty is that between Cyprus and the Soviet Union.

28. The applicable treaty is that between Cyprus and the ex-Yugoslavia.

29. The applicable treaty is that between Cyprus and ex Czechoslovakia.

30. Zero if the beneficial owner is a company which holds directly at least 10% of the capital of the paying company provided that is held for an uninterrupted period of not less than one year.

31. The treaty has been ratified and will enter into force during 2014.

32. The rate becomes 5% if the beneficial owner has invested in the capital of the company less than €150.000.

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

34. Zero if the beneficial owner is a company which holds directly at least 10% of the capital of the paying company provided that is held for an uninterrupted period of not less than one year.

Zero if the beneficial owner is the other Contracting State, its Central Bank or any agency including financial institutions owned or controlled by the Government of that other State.

Zero if the beneficial owner is a pension fund or other similar institution providing pension schemes established, recognized for tax purposes and controlled in accordance with the laws of that other State.

15% in all other cases.

35. Zero if the beneficial owner is a company which holds directly at least 10% of the capital of the paying company and 5% in all other cases.

36. Zero if the beneficial owner is a company which holds directly at least 10% of the capital of the paying company provided that is held for an uninterrupted period of not less than two years and 5% in all other cases.

37. 5% if the dividend is received by a company which controls directly at least 10% of the voting rights of the paying company and 15% in all other cases.