Double Tax Treaties
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 |
- Under Cyprus legislation there is no withholding tax on dividends, interests and royalties paid to non-residents of Cyprus.
- In case where royalties are earned on rights used within Cyprus there is withholding tax of 10%.
- 5% on film and TV royalties.
- Nil if paid to a Government, Central Bank, Public Authority or for export guarantee.
- Nil on literary, dramatic, musical or artistic work.
- Nil if paid to the Government of the other state.
- 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.
- 15% if received by a company controlling less than 25% of the voting power or by an individual.
- 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%.
- Nil if paid to a Government bank or financial institution.
- 5% on film royalties.
- 5% if received by a company controlling less than 50% of the voting power and in all cases if received by an individual.
- 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.
- 10% for payments of a technical, managerial or consulting nature.
- Treaty rate 15%. However, the max WHT per Cyprus tax legislation is 10% (refer to note 2).
- 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.
- 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.
- No withholding tax for interest on deposits with banking institutions.
- 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.
- 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.
- 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.
- 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%.
- 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.
- 7% if paid to bank or financial institution.
- Montenegro and Serbia apply the Yugoslavia/Cyprus treaty.
- This rate applies if received by a company (excluding partnership) which holds directly 25% of the shares. 10% rate applies in all other cases.
- 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
- 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.
- 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.
- A rate of 5% if a dividend is paid by a company in which the beneficial owner has invested less than EUR 150.000.
- The provisions of the Parent-Subsidiary EU directive are applicable.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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
- Parent / Subsidiary Directive
- Interest Directive
- Royalties directive
These EU Directives allow a Cyprus company to receive dividends, interest and royalties from its EU subsidiaries without deduction of withholding tax.