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Double Tax Treaties

Cyprus has a large network of double income tax treaties which reduce significantly withholding taxes for payments outside of treaty countries. A summary of the main withholding tax rates can be found below:
 
  Received in Cyprus
  Dividends Interest Royalties
  % % %
Armenia 0/5 (32) 5 (33) 5  
Austria 10   0   0  
Belarus 5/10/15 (4) 5   5  
Belgium 10/15 (1) 10 (16) 0  
Bulgaria 5 (19) 7 (25) 10 (20)
Canada 15   15 (7) 10 (11)
China 10   10   10  
Czech Republic 0 (30) 0   10  
Denmark 0 (34) 10 (9) 0  
Egypt 15   15   10  
Esthionia(35) 0   0   0  
Finland 5/15 (37) 0   0  
France 10 (2) 10 (9) 0 (26)
Germany 5 (2) 0   0  
Greece 25   10   0 (12)
Geurnsey(31) 0   0   0  
Hungary 5 (1) 10 (8) 0  
India 10 (2) 10 (8) 15 (15)
Ireland 5/15   0   0 (12)
Iceland 5/15 (39) 0   5  
Italy 15   10   0  
Kuwait 10   10 (8) 5 (14)
Kyrgyzstan (27) 0   0   0  
Lebanon 5   5 (16) 0  
Lithuania 0/5 (40) 0   5  
Malta 0 (22) 10 (8) 10  
Mauritius 0   0   0  
Moldova 5 (19) 5   5  
Montenegro (28) 10   10   10  
Norway 0/5 (3) 0   0  
Poland 0 (36) 5 (8) 5  
Portugal 10   10   10  
Qatar 0   0   5  
Romania 10   10 (8) 5 (14)
Russia 5 (6) 0   0  
San Marino 0   0   0  
Serbia (28) 10   10   10  
Seychelles 0   0   5  
Singapore 0   10 (23) 10  
Slovakia (29) 10   10 (8) 5 (14)
Slovenia 5   5 (33) 5  
South Africa 0   0   0  
Spain 0 (35) 0   0  
Sweden 5 (1) 10 (8) 0  
Switzerland (31) 0 (38) 0   0  
Syria 0 (1) 10 (8) 15 (13)
Tajikistan (27) 0   0   0  
Thailand 10 15 10 (17) 5 (18)
Ukraine 5 (21) 2   5  
United Arab Emirates 0   0   0  
United Kingdom 0 (24) 10   0 (26)
USA 5/15 (5) 10 (10) 0  
Uzbekistan (27) 0 (21) 0   0  
 
  Paid from Cyprus *
  Dividends Interest Royalties
  % % %
Non-Treaty Countries 0   0   0 **
Armenia 0 (32)  (33)  
Austria 10   0   0  
Belarus 5 (4) 5   5  
Belgium 10 (1) 10 (16) 0  
Bulgaria 5 (19) 7 (25) 10 (20)
Canada 15   15 (7) 10 (11)
China 10   10   10  
Czech Republic 0 (30) 0   10  
Denmark 0 (34) 0 (9) 0  
Esthionia(35) 0   0   0  
Finland 5/15 (34) 0   0  
Egypt 15   15   10  
France 10 (2) 10 (9) 0 (26)
Germany 5 (2) 0   0  
Greece 25   10   0 (12)
Guernsey (31) 0   0   0  
Hungary 5   10 (8) 0  
India 10 (2) 10 (8) 15 (15)
Ireland 0   0   0 (12)
Iceland 5 (39) 0   5  
Italy 15   10   0  
Kuwait 10   10 (8) 5 (14)
Kyrgyzstan (27) 0   0   0  
Lebanon 5   5 (16) 0  
Lithuania 0 (40) 0   5  
Malta 15   10 (8) 10  
Mauritius 0   0   0  
Moldova 5 (19) 5   5  
Montenegro (28) 10   10   10  
Norway 0   0   0  
Poland 0 (36) 5 (8) 5  
Portugal 10   10   10  
Qatar 0   0   5  
Romania 10   10 (8) 5 (14)
Russia 5 (6) 0   0  
San Marino 0   0   0  
Serbia (28) 10   10   10  
Seychelles 0   0   5  
Singapore 0   10 (23) 10  
Slovakia (29) 10   10 (8) 5 (14)
Slovenia 5   5 (33) 5  
South Africa 0   0   0  
Spain 0 (35) 0   0  
Sweden 5 (1) 10 (8) 0  
Switzerland (31) 0 (38) 0   0  
Syria 0 (1) 10 (8) 15 (13)
Tajikistan (27) 0   0   0  
Thailand 10   10 (15) 5 (18)
Ukraine 0   0   0  
United Arab Emirates 0   0   0  
United Kingdom 0   10   0 (26)
USA 0   10 (10) 0  
Uzbekistan (27) 0   0   0

 

 

Double Tax Treaties

Notes

*Payments of dividends and interest to non residents are exempt from withholding tax in Cyprus. Royalties granted for use outside of Cyprus are also free of withholding tax in Cyprus.
** 10% in the case of royalties granted for use within the Republic. 5% on film and TV rights.

  1. 15% if received by a company controlling less than 25% of the voting power.
  2. This rate if received by a company controlling more than or equal to 10% of the voting power. A rate of 15% in all other cases.
  3. NIL rate applies if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends or if the beneficial owner of the shares is the Government of Cyprus or Norway. A rate of 15% in all other cases.
  4. 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%.
  5. 5% if received by a company controlling at least 10% of the voting power. A rate of 15% in all other cases.
  6. 10% if received by company, which has invested less than €100.000.
  7. NIL if paid to the Government or for export guarantee.
  8. NIL if paid to the Government of the other State or to a financial institution.
  9. NIL if paid to the Government of the other State or in connection with the sale on credit of any industrial, 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.
  10. NIL 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.
  11. NIL on literary, dramatic, musical or artistic work apart from films that are used in TV programs
  12. 5% on film royalties (except films shown on TV).
  13. 10% on literary, dramatic, musical, artistic work, films and TV royalties.
  14. NIL on literary, artistic or scientific work including films.
  15. 10% on payment of technical fees, management fees and consultancy fees.
  16. NIL 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.
  17. 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.
  18. 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.
  19. 5% if received by a company, which owns at least 25% of the capital of the company paying the dividends. A rate of 10% in all other cases
  20. This rate does not apply, where 25% or more of the 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.
  21. 5% of the gross dividend if the beneficial owner is a company which holds directly 20% of the capital of the company paying the dividends or has invested to the purchase of shares or similar rights of the company an amount equal to €100.000. 15% in all other cases.
  22. 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.
  23. 7% if paid to a bank or similar financial institution. NIL if paid to the government.
  24. The treaty provides for 15% withholding tax but the local taxation provides for 0% withholding tax.
  25. NIL if paid to or is guaranteed by the government, statutory body, the Central Bank
  26. 5% on film royalties, including films used for television programs
  27. The Treaty between the Republic of Cyprus and the United Soviet Socialist Republic still applies
  28. The Treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia still applies
  29. The Treaty between the Republic of Cyprus and the Czechoslovak Socialist Republic still applies.
  30. Nil if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends where such holding is being possessed for an uninterrupted period of no less than one year. 5% in all other cases.
  31. A new treaty has been signed which provides for changes in the above rates but which has not come into force yet.
  32. 5% if the beneficial owner has invested in the capital of the company less than the equivalent of €150.000 at the time of the investment.
  33. Nil if paid to the Government or to the local authority, or to the Central Bank.
  34. Nil if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends, where such holding is being possessed for an uninterrupted period of no less than 12 months.

    Nil if the beneficial owner is the other Contracting State or the Central Bank of that other State, or any national agency or any other agency (including a financial institution) owned or controlled by the Government of that other State.

    Nil if the beneficial owner is a pension fund or other similar institution providing pension schemes in which individuals may participate in order to secure retirement benefits, where such pension fund or other similar institution is established, recognized for tax purposes and controlled in accordance with the laws of that other State. 15% in all other cases.
  35. Nil if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital. 5% in all other cases.
  36. Nil if the beneficial owner is a company(other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends, where such holding is being possessed for an uninterrupted period of no less than 24 months. 5% in all other cases.
  37. 5% if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital, with voting rights of the company paying the dividends. 15% in all other cases.
  38.  Nil if the beneficial owner is
    • a company (other than a partnership) which its capital is divided fully or partly to shares and which holds directly at least 10% of the capital ofthe company paying the dividends paying the dividends for at least a year or
    • provident fund or any other similar institution which is recognized for tax purposes, or
    • the Government, local authority, political department or the Central Bank of the two contractual states.
  39. 5% if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital, of the company paying the dividends. 10% in all other cases.
  40. Nil if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital, of the company paying the dividends. 5% in all other cases.

  International Double Tax Treaties with Cyprus