Cyprus Double Tax Treaties
DeltaQuest can assist you whether you are an individual or corporate entity in setting up a Cyprus trust or Cyprus foundation to achieve complete and comprehensive asset protection. For more information about Cyprus tax treaties, please read the information below. Alternatively, to establish a Cyprus Trust or foundation please complete our Application Form, or if you require further information please Contact Us.
The Cyprus double tax treaties have been drafted very closely to the Organisation in Economic Cooperation and Development (OECD) Model Treaty. The OECD model has been changed where necessary in order to conform with the tax systems of the countries concerned.
Cyprus has entered into a number of double tax treaties for the avoidance of double taxation. The purpose of these treaties is the avoidance of double taxation of income earned in any of these countries.
| Summary of Withholding Tax Rates | ||||||
| Country | Paid from Cyprus to residents of the following countries | Paid from the following countries to residents of Cyprus | ||||
| Dividends % | Interest % | Royalties % | Dividends % | Interest % | Royalties % | |
| Austria | 10 | 0 | 0 | 10 | 0 | 0 |
| Belarous | 10(17) | 5 | 5 | 10(17) | 5 | 5 |
| Belgium | - | - | - | 0 | 0 | 0 |
| Bulgaria | 0 | 0 | 0 | 0 | 0 | 0 |
| Canada | 0 | 15(7) | 10(12) | 15 | 15(7) | 10(12) |
| China | 10 | 10 | 10 | 10 | 10 | 10 |
| C.I.S (Ex-USSR) | 0 | 0 | 0 | 0 | 0 | 0 |
| Czech Republic | 0 | 10(7) | 5(8) | 10 | 10(7) | 5(8) |
| Denmark | 10(1) | 10(7) | 0 | 10(1) | 10(7) | 0 |
| Egypt | 15 | 15 | 10 | 15 | 15 | 10 |
| France | 0 | 10(7) | 0(10) | 10(2) | 10(7) | 0(10) |
| Germany | 0 | 10(7) | 0(10) | 15(3) | 10(7) | 0(10) |
| Greece | 25 | 10 | 0(9) | 25 | 10 | 0(9) |
| Hungary | 0 | 10(7) | 0 | 5(4) | 10(7) | 0 |
| India | 10(2) | 10(7) | 15 | 10(2) | 10(7) | 15 |
| Ireland | 0 | 0 | 0(9) | 0 | 0 | 0(9) |
| Italy | 0 | 10 | 0 | 15 | 10 | 0 |
| Kuwait | 0 | 10(7) | 5(8) | 10 | 10(7) | 5(8) |
| Malta | 15 | 10(7) | 10 | 0 | 10(7) | 10 |
| Mauritius | 0 | 0 | 0 | 0 | 0 | 0 |
| Norway | 0 | 25(14) | 0 | 5(5) | 0(15) | 0 |
| Poland | 10 | 10(7) | 5 | 10 | 10(7) | 5 |
| Romania | 10 | 10(7) | 5(8) | 10 | 10(7) | 5(8) |
| Russia | 5 | 0 | 0 | 5 | 0 | 0 |
| Slovak Republic | 0 | 10(7) | 5(8) | 10 | 10(7) | 5(8) |
| Singapoore | 0 | 10 | 10 | 0 | 10 | 10 |
| South Africa | 0 | 0 | 0 | 0 | 0 | 0 |
| Sweden | 5(4) | 10(7) | 0 | 5(4) | 10(7) | 0 |
| Syria | 15(16) | 10(7) | 10(17) | 15(16) | 10(7) | 10(17) |
| United Kingdom | 0 | 10 | 0(10) | 15(6) | 10 | 0(10) |
| U.S.A | 0 | 10(7) | 0 | 5(13) | 10(7) | 0 |
| Former Yugoslavia | 0 | 10 | 10 | 10 | 10 | 10 |
| Other Countries | 0-40(14) | 0-40(14) | 10(11) | (15) | (15) | (15) |
*The numbers in brackets refer to explanatory notes:
Explanatory Notes:
1.) 10% if recipient is a company with at least 25% direct share interest (15% in all other cases).
2.) 10% if recipient is a company with at least 10% direct share interest (15% in all other cases).
3.) 10% if recipient is a company with at least 25% direct share interest. If recipient is a company with more than direct or indirect share interest and the German corporation tax on distributed profits is lower than that on undistributed profits while the difference between the two rates is 15% or more, the rate is 27%(15% in all other cases).
4.) 5% if recipient is a company with at least 25% direct share interest (15% in all other cases).
5.) Nil if received by a company, which controls, directly or indirectly, not less than 50% of the voting power.
6.) A resident of Cyprus other than a company, which either alone or together with one or more associated companies controls directly or indirectly at least 10% of the voting power, is entitled to a tax credit in respect of the dividend. Where a resident of Cyprus is entitled to a tax credit, tax may also be charged on the aggregate of the cash dividend and the tax credit at a rate not exceeding 15%. In this case any excess tax credit is repayable. Where the recipient is not entitled to a tax credit, the cash dividend is exempt from any tax.
7.) Subject to certain exemptions.
8.) Nil if royalties are on literary, artistic or scientific work including cinematographic films and films or tapes for television or radio broadcasting.
9.) 5% on cinematographic films not including television films.
10.) 5% on cinematographic films including television films and videotapes for television.
11.) 5% on cinematographic films.
12.) Nil if royalties are copyright and other literary, dramatic, musical or artistic work not including film or videotape royalties.
13.) 5% if recipient is a company with at least 10% direct share interest; 15% in all other cases.
14.) There is a withholding tax of 20% on dividends and 25% on interest. The final tax liability is determined as follows :
(a) Companies: in respect of dividends, refundable on application. For interest, on application in accordance with corporate tax rates;
(b) Individuals : on objection, in accordance with personal tax rates. In both cases any excess tax withheld is refunded.
N.B. The agents or recipients of interest or dividends are liable for the payment of the due amount of tax on such income.
15.) At the rate applicable in accordance with domestic law.
16.) Nil if shareholder is a company that holds directly at least 25% of the capital of the company paying the dividends; 15% in all other cases.
17.) 15% for any patent, trade mark, design or model, plan, secret formula or process or any industrial, commercial, or scientific equipment or for information concerning industrial, commercial or scientific experience.
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