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 Cyprus - Armenia Double Tax Treaty ARMENIA 17/01/2011 19/09/2011 4145 05/09/2011 5% - 30 5% 5% - 30 5%
2 Cyprus - Austria Double Tax Treaty AUSTRIA 20/03/1990 10/11/1990 2500 27/04/1990 - 10% - - 10% -
3 Cyprus - Azerbaijan *** Double Tax Treaty AZERBAIJAN *** 29/10/1982 26/08/1983 26/11/1982 - - - - - -
4 Cyprus - Belarus Double Tax Treaty BELARUS 29/05/1998 12/02/1999 3273 09/10/1998 5% 5% 17 5% 5% 5% 17 5%
5 Cyprus - Belgium Double Tax Treaty BELGIUM 14/05/1996 08/12/1999 3365 19/11/1999 10% 6,18 10% 8 - 10% 6,18 10% 8 -
6 Cyprus - Bulgaria Double Tax Treaty BULGARIA 30/10/2000 03/01/2001 3461 30/12/2000 7% 6 5% 22 10% 7% 6,23 5% 22 10% 23
7 Cyprus - Canada Double Tax Treaty CANADA 02/05/1984 03/09/1985 2053 31/05/1985 15% 4 15% 10% 5 15% 4 15% 10% 5
8 Cyprus - China Double Tax Treaty CHINA 25/10/1990 05/10/1991 2578 22/02/1991 10% 10% 10% 10% 10% 10%
9 Cyprus - Czech Republic Double Tax Treaty CZECH REPUBLIC 15/04/1980 30/12/1980 1599 03/05/1980 - - 28 - 29 - - 28 - 29
10 Cyprus - Denmark Double Tax Treaty DENMARK 26/05/1981 10/08/1981 1704 17/07/1981 - - 6,32 - - - 6,32 -
11 Cyprus - Egypt Double Tax Treaty EGYPT 18/12/1993 14/03/1995 2865 11/03/1994 15% 15% 10% 15% 15% 10%
12 Cyprus - Estonia Double Tax Treaty ESTONIA 15/10/2012 01/01/2014 4146 01/02/2013 - - - - - -
13 Cyprus - Finland Double Tax Treaty FINLAND 15/11/2012 01/01/2014 4167 22/03/2013 - 5% 35 - - 5% 35 -
14 Cyprus - France Double Tax Treaty FRANCE 18/12/1981 01/04/1983 1468 09/07/1982 10% 10 - - 3 10% 10 10% 36 - 3
15 Cyprus - Germany Double Tax Treaty GERMANY 09/05/1974 11/10/1977 1199 27/06/1975 - 5% 36 - - 5% 36 -
16 Cyprus - Greece Double Tax Treaty GREECE 30/03/1968 16/01/1969 651 10/05/1968 10% 25% - 11 10% 25% - 11
17 Cyprus - Hungary Double Tax Treaty HUNGARY 30/11/1981 24/11/1982 862 07/05/1982 10% 6 - - 10% 6 5% 8 -
18 Cyprus - India Double Tax Treaty INDIA 13/06/1994 21/12/1994 2921 04/11/1994 10% 10 10% 37 10% 15 10% 10 10% 37 15% 14
19 Cyprus - Ireland Double Tax Treaty IRELAND 24/09/1968 12/07/1970 726 19/05/1969 - - - 11 - - - 11
20 Cyprus - Italy Double Tax Treaty ITALY 24/04/1974 09/06/1983 1586 05/09/1980 10% - - 10% 15% -
21 Cyprus - Kuwait Double Tax Treaty KUWAIT 15/12/1984 25/09/1986 2026 18/01/1985 10% 6 10% 5% 7 10% 6 10% 5% 7
22 Cyprus - Kyrgyzstan *** Double Tax Treaty KYRGYZSTAN *** 29/10/1982 26/08/1983 26/11/1982 - - - - - -
23 Cyprus - Lebanon Double Tax Treaty LEBANON 18/02/2003 14/04/2005 3976 08/04/2005 5% 5% - 5% 5% -
24 Cyprus - Malta Double Tax Treaty MALTA 22/10/1993 11/08/1994 2860 25/02/1994 10% 15% 10% 10% - 10%
25 Cyprus - Mauritius Double Tax Treaty MAURITIUS 21/01/2000 12/06/2000 3410 02/06/2000 - - - - - -
26 Cyprus - Moldova Double Tax Treaty MOLDOVA 28/01/2008 03/09/2008 4098 29/08/2008 5% 5% 26 5% 5% 5% 26 5%
27 Cyprus - Montenegro * Double Tax Treaty MONTENEGRO * 29/06/1985 08/09/1986 2073 23/08/1985 10% 10% 10% 10% 10% 10%
28 Cyprus - Norway Double Tax Treaty NORWAY 02/05/1951 01/01/1955 11/06/1956 - - - - - 12 -
29 Cyprus - Poland Double Tax Treaty POLAND 04/06/1992 09/07/1993 2735 04/09/1992 5% 6 - 34 5% 5% 6 - 34 5%
30 Cyprus - Portugal Double Tax Treaty PORTUGAL 19/11/2012 01/01/2014 4167 22/03/2013 10% 10% 10% 10% 10% 10%
31 Cyprus - Qatar Double Tax Treaty QATAR 11/11/2008 20/03/2009 4099 14/11/2008 - - 5% 27 - - 5% 27
32 Cyprus - Romania Double Tax Treaty ROMANIA 16/11/1981 08/11/1982 1757 26/02/1982 10% 6 10% 5% 7 10% 6 10% 5% 7
33 Cyprus - Russia Double Tax Treaty RUSSIA 05/12/1998 17/08/1999 3306 26/02/1999 - 5% 16 - - 5% 16 -
34 Cyprus - San Marino Double Tax Treaty SAN MARINO 27/04/2007 18/07/2007 4088 13/07/2007 - - - - - -
35 Cyprus - Serbia * Double Tax Treaty SERBIA * 29/06/1985 08/09/1986 2073 23/08/1985 10% 10% 10% 10% 10% 10%
36 Cyprus - Seychelles Double Tax Treaty SEYCHELLES 28/06/2006 27/10/2006 25/10/2006 - - 5% - - 5%
37 Cyprus - Singapore Double Tax Treaty SINGAPORE 24/11/2000 08/02/2001 3641 30/12/2000 10% 6,24 - 10% 10% 6,24 - 10%
38 Cyprus - Slovakia ** Double Tax Treaty SLOVAKIA ** 15/04/1980 30/12/1980 1599 03/05/1980 10% 6 10% 5% 7 10% 6 10% 5% 7
39 Cyprus - Slovenia * Double Tax Treaty SLOVENIA * 29/06/1985 08/09/1986 2073 23/08/1985 5% 5% 31 5% 5% 5% 31 5%
40 Cyprus - South Africa Double Tax Treaty SOUTH AFRICA 26/11/1997 08/12/1998 3214 16/01/1998 - - - - - -
41 Cyprus - Spain Double Tax Treaty SPAIN 14/02/2013 01/01/2014 4167 22/03/2013 - - - - - -
42 Cyprus - Sweden Double Tax Treaty SWEDEN 22/10/1988 14/11/1989 2377 20/01/1989 10% 6 5% 8 - 10% 6 5% 8 -
43 Cyprus - Syria Double Tax Treaty SYRIA 15/03/1992 22/02/1995 2863 04/03/1994 10% 4 - 8 10% 10% 4 - 8 10%
44 Cyprus - Thailand Double Tax Treaty THAILAND 27/10/1998 04/04/2000 3394 17/03/2000 15% 20 10% 5% 21 15% 20 10% 5% 21
45 Cyprus - Tajikistan *** Double Tax Treaty TAJIKISTAN *** 29/10/1982 26/08/1983 26/11/1982 - - - - - -
46 Cyprus - Ukraine *** Double Tax Treaty UKRAINE *** 29/10/1982 26/08/1983 26/11/1982 2% 5% 19 5% 33 2% 5% 19 5% 33
47 Cyprus - United Arab Emirates Double Tax Treaty UNITED ARAB EMIRATES 27/02/2011 00/01/1900 4145 05/09/2011 - - - - - -
48 Cyprus - United Kingdom Double Tax Treaty UNITED KINGDOM 20/06/1974 01/11/1974 1107 05/07/1974 10% - - 3 10% 15% 13 - 3
49 Cyprus - USA Double Tax Treaty USA 19/03/1984 31/12/1985 1944 04/04/1984 10% 10 - - 10% 10 5% 9 -
50 Cyprus - Uzbekistan *** Double Tax Treaty 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.

Tags: tax treaties

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