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International Taxation

Cyprus Double Tax Treaties
 

Tax treaties withholding tax tables

The following tables give a summary of the withholding taxes provided by the double tax treaties entered into by Cyprus

 

Notes

  1. In accordance with the Cyprus tax legislation payments of dividends and interest to non Cyprus tax residents are exempted from withholding tax in Cyprus. Royalties granted for use outside Cyprus are also free of withholding tax in Cyprus.

  2. 10% in the case of royalties granted for use within the Republic. 5% on film and TV rights.

  3. 0% if dividends are distributed between associated companies of different EU member states, provided that the parent company shareholding is at least 10%.

  4. 0% if interest and royalties are paid between associated companies of different EU member states. The possibility for a transitional period for the implementation of the directive was granted to Czech Republic, Latvia, Lithuania, Poland and Slovakia.

  5. 15% if received by a company controlling less than 25% of the voting power.

  6. 15% if received by a company controlling less than 10% of the voting power.

  7. 0% if paid to a company controlling at least 50% of the voting power.

  8. 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 the paying company. Otherwise the rate is 15%.

  9. 5% if received by a company controlling at least 10% of the voting power.

  10. 10% if received by a company, which has invested less than US$ 100.000. The new double tax treaty provides for 10% rate for investments of less than € 100.000.

  11. 0% if paid to the Government or for export guarantee.

  12. 0% if paid to the Government of the other State or to a financial institution.

  13. 0% if paid to the Government of the other State or in connection with the sale on credit 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.

  14. 0% 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.

  15. 0% on literary, dramatic, musical or artistic work with the exception of films used for television programs.

  16. 5% on film royalties (except films shown on TV).

  17. 10% on literary, dramatic, musical, artistic work, films and TV royalties.

  18. 0% on literary, artistic or scientific work including films.

  19. 10% on payment of technical fees, management fees and consultancy fees.

  20. 0% 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.

  21. 10% on interest received from financial institutions, on interest paid in connection with industrial, commercial, scientific equipment or the sale or merchandise between two companies.

  22. 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.

  23. 10% if received by a company, which owns directly less than 25% of the share capital.

  24. This rate does not apply where 25% or more of the share 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.

  25. The treaty provides for 25%, but the domestic rate of 0% applies since it is lower than the treaty rate.

  26. 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.

  27. 7% if paid to a bank or similar financial institution. 0% if paid to the government.

  28. The treaty provides for 15% withholding tax but the local taxation provides for 0% withholding tax.

  29. 0% if paid to or is guaranteed by the government, statutory body, the Central Bank.

  30. 5% on film royalties, including films used for television programs.

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

  32. The treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia still applies.

  33. 5% if the holding is less than 10%.
 
 
 
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