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Tax Planning for Investment in Central and Eastern Europe

\"Cyprus

The revolutionary events throughout Central and Eastern Europe continue to have a profound effect on businesses worldwide. The opportunities for western companies are unprecedented and as the economic restructuring of the Central and East European countries continues, many new opportunities and challenges are created.

The unique network of Cyprus double tax treaties with almost all Central and East European countries in conjunction with the tax advantages offered to Cyprus businesses and ship owning companies, make Cyprus an ideal stepping stone for western investors intending to do business or invest in Central and Eastern Europe.

The table below shows the withholding tax rates applicable to payments out of these countries to Cyprus as compared to the withholding tax applicable to non-treaty countries.
 

WITHHOLDING TAXES ON PAYMENTS FROM
CENTRAL AND EASTERN EUROPE

Country

Dividends

Interest

Royalties

 

 To
Cyprus
%

To
Non-treaty countries(1)
%

 To
Cyprus
%

To
Non-treaty countries(1)
%

To
Cyprus
%

To
Non-treaty countries(1)
%

Armenia 0 0 0 10 0 10
Belarus 5/10/15 15 5 10 5 15
Bulgaria 5 5 7 10 10 10
Czech Republic 10 15 10 15 5 15
Hungary 0 0 10 0 0 0
Kyrgyzstan 0 10 0 10 0 30
Montenegro 10 15 10 5 10 15
Poland 10 19 10 20 5 20
Romania 10 16 10 16 5 16
Russia 5 15 0 20 0 20
Serbia 10 15 10 15 10 15
Slovakia 10 0 10 19 5 19
Slovenia 10 15 10 15 10 15
Tajikistan 0 12 0 12 0 15
Ukraine 0 15 0 15 0 15
Uzbekistan 0 10 0 10 0 20

Notes:
  1. The non-treaty rate depends on the law of each state and it may be subject to change.