CYPRUS DOUBLE TAX TREATIES

The following table is a summary of the applicable withholding tax rates for the income between countries having a double taxation treaty with Cyprus. The tax rates below are valid under certain conditions which are determined by the provisions of each agreement.

TABLE OF CYPRUS WITHHOLDING TAX RATES (CYPRUS DOUBLE TAX TREATIES TABLE)

	Received in Cyprus			Paid from Cyprus(1)
Treaty  country	Divident	Interest	Royalt	Divident	Interest	Royalt
Andorra	0	0	0	0	0	0
Armenia	0(24)	5	5	0(24)	5	5
Austria	10	0	0	10	0	0
Azerbaijan (36)	0	0	0	0	0	0
Bahrain	0	0	0	0	0	0
Bailiwick of Guernsey	0	0	0	0	0	0
Barbados (31)	0	0	0	0	0	0
Belarus	5(14)	5	5	5(14)	5	5
Belgium	10(5)	10(4,39)	0	10(5)	10	0
Bosnia(25),(44)	10	10	10	10	10	10
Bulgaria	5(20)	7(4,23)	10(23)	5(20)	7(4)	10
Canada	15	15(3)	10(12)	15	15(3)	10(12)
China	10	10	10	10	10	10
CzechRepublic	0(27)	0	0(28)	0(27)	0	0(28)
Denmark (29)	0(40)	0	0	0(40)	0	0
Egypt(43)	5	10	10	5	10	10
Estonia	0	0	0	0	0	0
Ethiopia	5	5(4)	5	5	5(4)	5
France	10(6)	10(7)	0(2)	10(6)	10(7)	0(2)
Finland	5(33)	0	0	5(33)	0	0
Georgia	0	0	0	0	0	0
Germany	5(6)	0	0	5(6)	0	0
Greece	25(8)	10	0(9)	25	10	0(9)
Guernsey	0	0	0	0	0	0
Holand (54)	5(53)	0	0	5(53)	0	0
Hungary	5(5)	10(4)	0	0	10(4)	0
Iceland	5(34)	0	5	5(34)	0	5
India (47)	10(6)	10(7)	15(11)	10(6)	10(7)	15(11)
Iran	5(44)	5(4)	6	5(44)	5(4)	6
Ireland	0	0	0(9)	0	0	0(9)
Italy	15	10	0	0	10	0
Jersey	0	0	0	0	0	0
Jordan	5(60)	5(59)	7	5(60)	5(59)	7
Kazakhstan(43+45)	5(33)	0(51)	10	5(33)	0(51)	10
Kuwait	0	0	5	0	0	5
Kyrgyzstan (36)	0	0	0	0	0	0
Latvia	0(47)	0(48)	0(49)	0(47)	0(48)	0(49)
Lebanon	5	5(15)	0	5	5(15)	0
Lithuania	0(37)	0	5	0(37)	0	5
Luxembourg	05(37)	0	0	0	0	0
Malta	0	10(7)	10	15	10(4)	10
Mauritius	0	0	0	0	0	0
Moldova	5(20)	5	5	5(20)	5	5
Montenegro(25),(44)	10	10	10	0	0	0
Norway	0(16)	0	0	0	0	0
Poland	10(41)	5(4)	5	0(38)	5(4)	5
Portugal	10	10	10	10	10	10
Qatar	0	0	5	0	0	5
Romania	10	10(4)	5(13)	10	10(4)	5(13)
Russia	15(17)	15(56)	0	15(17)	15(56)	0
San Marino	0	0	0	0	0	0
Saudi Arabia	0/5(57)	0	5/8(58)	0/5(57)	0	5/8(58)
Serbia	10	10	10	10	10	10
Seychelles	0	0	5	0	0	5
Singapore	0	10(18)	10	0	10(18)	10
Slovakia (30)	10	10(4)	5(13)	10	10(4)	5(13)
Slovenia	5	5	5	5	5	5
South Africa	0	0	0	10	0	0
Spain	0(35)	0	0	0(35)	0	0
Sweden	5(5)	10(4)	0	5(5)	10(4)	0
Swiss Confederation	0(40)	0	0	0(40)	0	0
Syria	0(5)	10(4)	15(19)	0(5)	10(4)	15(19)
Tajikistan(36)	0	0	0	0	0	0
Thailand	10	10(21)	5(22)	10	10(21)	5(22)
Ukraine(46)	5(32)	5	5(42)	5(32)	5	5
United Arab Emirates	0	0	0	0	0	0
United Kingdom	15(10)	0	0(2)	0	0	0(2)
United States of America	15(26)	10(7)	0	0	10(7)	0
Uzbekistan(36)	0	0	0	0	0	0

Cyprus double tax treaties notes:

1. Dividends and interest paid to non-residents of Cyprus, as well as royalties payable abroad and granted for use outside Cyprus are exempt from any  Cyprus withholding tax.

2. 5% applies only to television and film rights.

3. 0% applies if it is paid to a Government or for export guarantee.

4. 0% applies if it is paid to the Government of the contracting state.

5. 15% applies if it is received by a company that controls less than 25% of the voting rights and in all cases if received by an individual.

6. 15% applies if it is received by a company that controls less than 10% of the voting rights and in all cases if received by an individual.

7. 0% applies if it is paid to a Government, a financial institution or a bank of the contracting state.

8. The double tax treaty between Cyprus and Greece provides 25% withholding tax but according to the legislation of Greece 10% tax is withheld from 1/1/2009.

9. 5% applies only to film rights.

10. The double tax treaty between Cyprus and the United Kingdom provides 15% withholding tax no tax is withheld on dividends according to the legislation of the United Kingdom. Companies controlling at least 10% of the voting rights are not entitled to withholding tax.

11. 10% applies for payments of a technical, administrative or advisory nature.

12. 0% applies to theatrical, musical, literary or any other artistic work.

13. 0% applies for patents, production processes or any royalties arising from scientific research.

14. 15% applies in cases of investments which are less than €200.000. The withholding tax can be reduced to 10% if the investment is over 25% of the company’s share capital.

15. 0% applies if is paid to the Government of the contracting state or to any other institution, local authority and any bank which is owned entirely by the state.

16. 0% applies if it is received by a company (other than a partnership) holding at least 10% of the share capital of the company issuing the dividend or if it is paid to the Government of any of the two contracting states. 15% applies in all other cases.

17. 5% if the beneficial owner is an insurance company or pension fund, the Government, a political subdivision or a local authority, a Central Bank or a company whose shares are listed on a listed stock exchange provided that at least 15% of the voting shares are distributed to the general public and which directly owns at least 15% of the capital of the company paying the dividend for a period of 365 days including the date of payment of the dividend. 15% in all other cases.

18. 7% applies if it is paid to a bank or a relevant financial institution.

19. 10% applies to artistic, scientific and literary work.

20. 10 % applies if it is received by a company holding less than 25% of the share capital of the company issuing the dividend.

21. 10% applies on interest paid to a financial institution or on interest paid in connection with commercial, industrial or even scientific equipment

22. 10% applies on royalties in connection with commercial, industrial or even scientific equipment increases to 15% for patents, production processes or any other royalties arising from scientific research.

23. The rates apply when the payment is made to a Cyprus Company by a Bulgarian resident which holds directly or indirectly less than 25% of a Cyprus company’s share capital.

24. A rate of 5% if a dividend is paid by a company in which the beneficial owner has invested less than €150.000.

25. The provisions of the double tax treaty between the Republic of Cyprus and the former Socialist Federal Republic of Yugoslavia still apply. Bosnia also applies this provision.

26. 5% applies if it is received by a company that controls at least 10% of the voting rights.

27. Applies if it is received by a company owning directly 10% of the shares for an uninterrupted period of one year. In all other cases, 5% applies.

28.10% applies for the following: patent, trademark, design or model, plan, secret formula or process, computer software or industrial, commercial or scientific equipment, or for information concerning the commercial, industrial or scientific experience.

29. Under this treaty provisions no withholding tax will apply, assuming that the company holds at least 10% of share capital and for a minimum shareholding period of 12 months, otherwise a 15% withholding applies.

30. The treaty between the Republic of Cyprus and the Czechoslovak Socialist Republic still applies.

31. The treaty is effective from 1 January 2018.

32.15% applies if the investment is less than €100.000 and lower of 20% of the company’s share capital.

33. 5% applies if the recipient is a company that owns at least 10 % of the company distributing the dividends, with voting rights in the company distributing the dividends. In all other cases, 15% applies.

34.  5% applies if the recipient is a company that owns at least 10 % of the company distributing the dividends. In all other cases, 10% applies.

35. 0% applies if the dividend is received by a company holding at least 10% of the issued share capital. 5% applies in all other cases.

36. The treaty between the Republic of Cyprus and the United Soviet Socialist Republic still applies.

37. 0% applies if the beneficial owner is a company which holds directly at least 10% on the capital of the company paying the dividends. 5% applies in all other cases.

38. 0% applies if the beneficial owner is a company which holds directly at least 10% on the capital of the company paying the dividends, where such holding is being possessed for an interrupted period of 24 months. 5% applies in all other cases.

39. Nil withholding tax is applied to interests derived from deposits in financial institutions.

40. 0% applies if it is received by a company (other than a partnership) holding at least 10% of the share capital of the company issuing the dividend for a minimum shareholding period of 12 months, or if it is paid to the Government of any of the two contracting states, pension fund or any similar institution. 15% applies in all other cases.

41. The treaty is effective from 18 September 2015 but may apply retrospectively. 5% applies if the recipient is a company that owns at least 10 % of the company distributing the dividends. In all other cases, 10% applies.

42. 5% applies for royalties in respect of copyrights of scientific work, patent, trademark, secret formula, production process or information relating to industrial, commercial or scientific experience. 10% applies in all other cases.

43. The treaty has been published in the Gazette but has not come into force until the time of publication of this guide.

44. 5% applies if the recipient is a company that owns at least 25 % of the company distributing the dividends. In all other cases, 10% applies.

45. It was formed a new treaty, which is expected to be effective not earlier than 1/1/2021.

46. It was formed a new treaty, which is not signed yet.

47. 0% applies if it is received by a company (other than a partnership). 10% applies in all other cases.

48. 0% applies if it is received by a company (other than a partnership) or by the government of any of the two contracting states. 10% applies in all other cases.

49. 0% applies if it is received by a company (other than a partnership). 5% applies in all other cases.

50. Other than the Double Tax Agreements which are presently in force, the conclusion of various other Agreements is pending. These Agreements are currently under negotiation.

51. 0% applies if the beneficial owner is the Government of the other Contracting State or its political subdivisions or any central or local authority, or the Central Bank or any other Financial Organisation owned by the other Contracting State. 10% in all other cases.

52. 5% if the beneficial owner is a company that holds at least 20% of the capital of the company that pays the dividend for a period of 365 days. 10% in all other cases.

53. 0% if the beneficial owner is a company that directly owns at least 5% of the capital of the company that paid the dividends throughout the 365-day period including the day the dividend was paid. 0% if the beneficial owner is a recognized pension fund. 15% in all other cases.

54. Signed but not entered into force.

55. The American Protocol Implemented from 1/1/2021.

56. 0% if the beneficiary is an insurance entity or a pension fund, the Government, a political subdivision or a local authority, a Central Bank, or a Bank, or if it is paid in respect of securities listed on government or corporate bonds.  5% if the beneficiary is a company whose shares are listed on a stock exchange, provided that not less than 15% of its voting shares belong to the general public and which directly owns at least 15% of the company’s capital who pays the dividend for a period of 365 days, including the day of dividend payment.

57. 0% if the beneficiary is a company that directly or indirectly owns at least 25% of the capital of the company that pays the dividends. 5% in all other cases.

58. 5% on royalties paid for the use of industrial, commercial or scientific equipment. 8% in all other cases.

59. 0% if the beneficial owner is the Government, political subdivision, local authority or the Central Bank of  the other Contracting State.

60. 5% if the beneficiary is a company (excluding the partnership) that directly owns at least 10% of the capital of the company paying the dividend. 10% in all other cases.

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Last update: March 2022

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