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Double Tax Treaties

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

 

Country

Dividends1

Interest1

Royalties1

 

Paid from CY

Received in CY

Paid from CY

Received in CY

Paid from CY

Received in CY

 

%

%

%

%

%

%

 

 

 

 

 

 

 

Non –Treaty

Countries

nil

-

nil

-

nil2

-

Armenia 

nil30

nil30

5

5

5

5

Austria

10

10

nil

nil

nil

nil

Belarus

517

517

5

5

5

5

Belgium

108

108

106,18

106,18

nil

nil

Bulgaria

522

522

76

76,23

10

1023

Canada

15

15

154

154

105

105

China, P.R.

10

10

10

10

10

10

Czech Republic

nil28

nil28

nil

nil

nil29

nil29

Denmark

nil6,32

nil6,32

nil

nil

nil

nil

Egypt

15

15

15

15

10

10

Estonia

nil nil nil nil nil nil

Finland

5 (35) 5 (35) nil nil nil nil

France

nil

10 (36)

10 (10)

10 (10)

nil (3)

nil (3)

Germany

5 (36)

5 (36)

nil

nil

nil

nil

Greece

25

25

10

10

nil (11)

nil (11)

Hungary

nil

5 (8)

10 (6)

10 (6)

nil

nil

India

10 (37)

10 (37)

10 (10)

10 (10)

10 (15)

15 (14)

Ireland, Rep. of

nil

nil

nil

nil

nil (11)

nil (11)

Italy

nil

15

10

10

nil

nil

Kuwait

nil

nil

nil

nil

5

5

Lebanon

5

5

5

5

nil

nil

Malta

15

nil

10

10

10

10

Mauritius

nil

nil

nil

nil

nil

nil

Moldova 

5 (26)

5 (26)

5

5

5

5

Montenegro (25)

10

10

10

10

10

10

Norway

nil

nil (12)

nil

nil

nil

nil

Poland

nil (34)

nil (34)

5 (6)

5 (6)

5

5

Portugal

10 10 10 10 10 10

Qatar

nil

nil

nil

nil

5 (27)

5 (27)

Romania

10

10

10 (6)

10 (6)

5 (7)

5 (7)

Russia

5 (16)

5 (16)

nil

nil

nil

nil

San Marino

nil

nil

nil

nil

nil

nil

Serbia (25)

10

10

10

10

10

10

Seychelles

nil

nil

nil

nil

5

5

Singapore

nil

nil

10 (6, 24)

10 (6, 24)

10

10

Slovakia Republic

10

10

10 (6)

10 (6)

5 (7)

5 (7)

Slovenia 

5 (31)

5 (31)

5

5

5

5

South Africa

nil

nil

nil

nil

nil

nil

Spain (38)

nil (39) nil (39) nil nil nil nil

Sweden

5 (8)

5 (8)

10 (6)

10 (6)

nil

nil

Syria

nil (8)

nil (8)

10 (4)

10 (4)

10

10

Thailand

10

10

15 (20)

15 (20)

5 (21)

5 (21)

Ukraine 

5 (19)

5 (19)

2

2

5 (33)

5 (33)

United Kingdom

nil

15 (13)

10

10

nil (3)

nil (3)

United States

nil

5 (9)

10 (10)

10 (10)

nil

nil

 

Notes

  1. Under Cyprus legislation there is no withholding tax on dividends, interests and royalties paid to non-residents of Cyprus.
  2. In case where royalties are earned on rights used within Cyprus there is withholding tax of 10%.
  3. 5% on film and TV royalties.
  4. Nil if paid to a Government, Central Bank, Public Authority or for export guarantee.
  5. Nil on literary, dramatic, musical or artistic work.
  6. Nil if paid to the Government of the other state.
  7. This rate applies for patents, trademarks, designs or models, plans, secret formulas or processes, or any industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.
  8. 15% if received by a company controlling less than 25% of the voting power or by an individual.
  9. 15% if received by a company controlling less than 10% of the voting power of the paying company and in all cases if received by an individual. If a company controls at least 10% of the voting power of the paying company in order to benefit from the WHT rate of 5%, other conditions relating to the income of the paying company need to be satisfied, otherwise a WHT rate of 15%.
  10. Nil if paid to a Government bank or financial institution.
  11. 5% on film royalties.
  12. 5% if received by a company controlling less than 50% of the voting power and in all cases if received by an individual.
  13. This rate applies to individual shareholders regardless of their percentage of shareholding. Companies controlling less than 10% of the voting shares are also entitled to this rate. Companies controlling at least 10% of the voting shares are entitled to Nil WHT.
  14. 10% for payments of a technical, managerial or consulting nature.
  15. Treaty rate 15%. However, the max WHT per Cyprus tax legislation is 10% (refer to note 2).
  16. 10% if dividend paid by a company in which the beneficial owner has invested less than €100.000 in the share capital of the company paying the dividend.
  17. If investment is less than €200.000, dividends are subject to 15% withholding tax which is reduced to 10% if the recipient company controls 25% or more of the paying company.
  18. No withholding tax for interest on deposits with banking institutions.
  19. A rate of 15% if a dividend is paid by a company in which the Beneficial Owner holds less than 20% of the Share Capital of the paying company and the Beneficial Owner has invested less than €100.000. 
  20. 10% on interest received by a financial institution or when it relates to sale on credit of any industrial, commercial or scientific equipment or of merchandise.
  21. This rate applies for any copyright of literary, dramatic, musical, artistic or scientific work. 10% rate applies for industrial, commercial or scientific equipment. 15% rate applies for patents, trademarks, designs or models, plans, secret formulae or processes.
  22. This rate applies to companies holding directly at least 25% of the share capital of the company paying the dividend. In all other cases the withholding tax is 10%.
  23. This rate does not apply if the payment is made to a Cyprus international business entity by a resident of Bulgaria owning directly or indirectly at least 25% of the share capital of the Cyprus entity.
  24. 7% if paid to bank or financial institution.
  25. Montenegro and Serbia apply the Yugoslavia/Cyprus treaty.
  26. This rate applies if received by a company (excluding partnership) which holds directly 25% of the shares. 10% rate applies in all other cases.
  27. Applies to any consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), computer software, any patent, trade mark, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience
  28. This rate applies if received by a company (excluding partnership) which holds directly at least 10% of the share capital of the paying company for an uninterrupted period of no less than one year. 5% applies in all other cases.
  29. 10% for patent, trade mark, design or model, plan, secret formula or process, computer software or industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.
  30. A rate of 5% if a dividend is paid by a company in which the beneficial

    owner has invested less than EUR 150.000.

  31. The provisions of the Parent-Subsidiary EU directive are applicable.

  32. A rate of 15% if received by a company controlling less than 10% of the

    share capital of the paying company or the duration of any holding is

    less than one uninterrupted year. A rate of 15% also applies if received

    by an indivdual.

  33. A 5% WHT will be levied on payment of royalties in respect of any

    copyright of scientific work, any patent, trade mark, secret formula,

    process or information concerning industrial, commercial or scientific

    experience. 10% WHT will be levied in all other cases.

  34. This rate applies if the recipient company (partnership is excluded)

    holds directly 10% of the share capital of the paying company for an

    uninterrupted period of at least 2 years. 5% in all other cases.

  35. A rate of 15% applies if received by a company controlling less than

    10% of the voting power in the paying company and in all cases if

    received by an individual.

  36. A rate of 15% if received by a company holding less than 10% of the

    share capital of the paying company and in all cases if received by an

    individual.

  37. A rate of 15% if received by a company holding less than 10% of

    the shares of the paying company and in all cases if received by an

    individual.

  38. The treaty with Spain is expected to be effective during 2014 in

    relation to WHT. The WHT provisions of the treaty will be effective

    after the period of 3 months from the date of exchange of notes

    between the two countries.

  39. A rate of 5% if received by a company holding less than 10% of the

    share capital of the paying company and in all cases if received by an

    individual or a company not limited at least partly by shares.

 

European Union Directives

  1. Parent / Subsidiary Directive
  2. Interest Directive
  3. Royalties directive

 

These EU Directives allow a Cyprus company to receive dividends, interest and royalties from its EU subsidiaries without deduction of withholding tax.

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