Cyprus double tax treaties

nr.		country	date of signing	date in force	Gov. Gazette issue nr.	Gov. Gazette issue date	interest		dividends		royalties		interest		dividents		royalties
1		ARMENIA	17/01/2011	19/09/2011	4145	05/09/2011	5%		-	30	5%		5%		-	30	5%
2		AUSTRIA	20/03/1990	10/11/1990	2500	27/04/1990	-		10%		-		-		10%		-
3		AZERBAIJAN ***	29/10/1982	26/08/1983		26/11/1982	-		-		-		-		-		-
4		BELARUS	29/05/1998	12/02/1999	3273	09/10/1998	5%		5%	17	5%		5%		5%	17	5%
5		BELGIUM	14/05/1996	08/12/1999	3365	19/11/1999	10%	6,18	10%	8	-		10%	6,18	10%	8	-
6		BULGARIA	30/10/2000	03/01/2001	3461	30/12/2000	7%	6	5%	22	10%		7%	6,23	5%	22	10%	23
7		CANADA	02/05/1984	03/09/1985	2053	31/05/1985	15%	4	15%		10%	5	15%	4	15%		10%	5
8		CHINA	25/10/1990	05/10/1991	2578	22/02/1991	10%		10%		10%		10%		10%		10%
9		CZECH REPUBLIC	15/04/1980	30/12/1980	1599	03/05/1980	-		-	28	-	29	-		-	28	-	29
10		DENMARK	26/05/1981	10/08/1981	1704	17/07/1981	-		-	6,32	-		-		-	6,32	-
11		EGYPT	18/12/1993	14/03/1995	2865	11/03/1994	15%		15%		10%		15%		15%		10%
12		ESTONIA	15/10/2012	01/01/2014	4146	01/02/2013	-		-		-		-		-		-
13		FINLAND	15/11/2012	01/01/2014	4167	22/03/2013	-		5%	35	-		-		5%	35	-
14		FRANCE	18/12/1981	01/04/1983	1468	09/07/1982	10%	10	-		-	3	10%	10	10%	36	-	3
15		GERMANY	09/05/1974	11/10/1977	1199	27/06/1975	-		5%	36	-		-		5%	36	-
16		GREECE	30/03/1968	16/01/1969	651	10/05/1968	10%		25%		-	11	10%		25%		-	11
17		HUNGARY	30/11/1981	24/11/1982	862	07/05/1982	10%	6	-		-		10%	6	5%	8	-
18		INDIA	13/06/1994	21/12/1994	2921	04/11/1994	10%	10	10%	37	10%	15	10%	10	10%	37	15%	14
19		IRELAND	24/09/1968	12/07/1970	726	19/05/1969	-		-		-	11	-		-		-	11
20		ITALY	24/04/1974	09/06/1983	1586	05/09/1980	10%		-		-		10%		15%		-
21		KUWAIT	15/12/1984	25/09/1986	2026	18/01/1985	10%	6	10%		5%	7	10%	6	10%		5%	7
22		KYRGYZSTAN ***	29/10/1982	26/08/1983		26/11/1982	-		-		-		-		-		-
23		LEBANON	18/02/2003	14/04/2005	3976	08/04/2005	5%		5%		-		5%		5%		-
24		MALTA	22/10/1993	11/08/1994	2860	25/02/1994	10%		15%		10%		10%		-		10%
25		MAURITIUS	21/01/2000	12/06/2000	3410	02/06/2000	-		-		-		-		-		-
26		MOLDOVA	28/01/2008	03/09/2008	4098	29/08/2008	5%		5%	26	5%		5%		5%	26	5%
27		MONTENEGRO *	29/06/1985	08/09/1986	2073	23/08/1985	10%		10%		10%		10%		10%		10%
28		NORWAY	02/05/1951	01/01/1955		11/06/1956	-		-		-		-		-	12	-
29		POLAND	04/06/1992	09/07/1993	2735	04/09/1992	5%	6	-	34	5%		5%	6	-	34	5%
30		PORTUGAL	19/11/2012	01/01/2014	4167	22/03/2013	10%		10%		10%		10%		10%		10%
31		QATAR	11/11/2008	20/03/2009	4099	14/11/2008	-		-		5%	27	-		-		5%	27
32		ROMANIA	16/11/1981	08/11/1982	1757	26/02/1982	10%	6	10%		5%	7	10%	6	10%		5%	7
33		RUSSIA	05/12/1998	17/08/1999	3306	26/02/1999	-		5%	16	-		-		5%	16	-
34		SAN MARINO	27/04/2007	18/07/2007	4088	13/07/2007	-		-		-		-		-		-
35		SERBIA *	29/06/1985	08/09/1986	2073	23/08/1985	10%		10%		10%		10%		10%		10%
36		SEYCHELLES	28/06/2006	27/10/2006		25/10/2006	-		-		5%		-		-		5%
37		SINGAPORE	24/11/2000	08/02/2001	3641	30/12/2000	10%	6,24	-		10%		10%	6,24	-		10%
38		SLOVAKIA **	15/04/1980	30/12/1980	1599	03/05/1980	10%	6	10%		5%	7	10%	6	10%		5%	7
39		SLOVENIA *	29/06/1985	08/09/1986	2073	23/08/1985	5%		5%	31	5%		5%		5%	31	5%
40		SOUTH AFRICA	26/11/1997	08/12/1998	3214	16/01/1998	-		-		-		-		-		-
41		SPAIN	14/02/2013	01/01/2014	4167	22/03/2013	-		-		-		-		-		-
42		SWEDEN	22/10/1988	14/11/1989	2377	20/01/1989	10%	6	5%	8	-		10%	6	5%	8	-
43		SYRIA	15/03/1992	22/02/1995	2863	04/03/1994	10%	4	-	8	10%		10%	4	-	8	10%
44		THAILAND	27/10/1998	04/04/2000	3394	17/03/2000	15%	20	10%		5%	21	15%	20	10%		5%	21
45		TAJIKISTAN ***	29/10/1982	26/08/1983		26/11/1982	-		-		-		-		-		-
46		UKRAINE ***	29/10/1982	26/08/1983		26/11/1982	2%		5%	19	5%	33	2%		5%	19	5%	33
47		UNITED ARAB EMIRATES	27/02/2011	00/01/1900	4145	05/09/2011	-		-		-		-		-		-
48		UNITED KINGDOM	20/06/1974	01/11/1974	1107	05/07/1974	10%		-		-	3	10%		15%	13	-	3
49		USA	19/03/1984	31/12/1985	1944	04/04/1984	10%	10	-		-		10%	10	5%	9	-
50		UZBEKISTAN ***	29/10/1982	26/08/1983		26/11/1982	-		-		-		-		-		-

Notes:
¹ Under Cyprus legislation there is no WHT on dividends and interest when paid to non-residents of Cyprus.
² Royalties earned on rights used within Cyprus are subject to WHT of 10%.
³ A rate of 5% on film and TV royalties.
⁴ 0% if paid to a government / Central Bank / Public Authority or for export guarantee.
⁵ 0% on literary, dramatic, musical, or artistic work.
⁶ 0% if paid to the government / Central Bank / Public Authority of the other state.
⁷ Rate applicable to 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 A rate of 15% if received by a company holding less than 25% of the share capital of the paying company and in all cases if received by an individual.
⁹ A rate of 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 0% if paid to a government, bank, or financial institution.
¹¹ A rate of 5% on film royalties.
¹² A rate of 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 A rate of 10% for payments of a technical, managerial, or consulting nature.
¹⁵ Treaty rate is 15%; however, the maximum WHT per Cyprus tax legislation is 10% (refer to note 2).
¹⁶ A rate of 10% on dividend if 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% WHT which is reduced to 10% if the recipient company controls 25% or more of the paying company.
¹⁸ No WHT 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 A rate of 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. A 10% rate applies for industrial, commercial, or scientific equipment. A 15% rate applies for patents, trade marks, designs or models, plans, secret formulas, 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 WHT 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 A rate of 7% if paid to a bank or financial institution.
²⁵ Serbia, and Montenegro apply the Yugoslavia / Cyprus treaty.
²⁶ This rate applies if received by a company (excluding partnerships) that holds directly 25% of the shares. A rate of 10% 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, trademark, 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, trademark, 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 €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 atleast 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.