Notes on Tax Treaties

* PAYMENT 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.

***Kyrgyztan, Tajikistan and Uzbekistan consider themselves bound by the treaty signed with the former USSR. The rate shown are those of the treaty Cyprus/USSR.

1. 15% if received by a company controlling less than 25% of the voting power.
2. 15% if received by a company controlling less than 10% of the voting power and in all case if received by an individual.
3. NIL if paid to a company controlling at least 50% of the voting power.
4. This rate applies if the amount invested by the beneficial owner is over EUR 200.000 irrespective of the % of the 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.
6. 10% if received by company, which has invested less than Euro 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 enterprises 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.
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. 10% if received by a company, which owns less than 25% of the capital.
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 Cyprus company pays less than the normal rate of tax.
21. 7% if paid to a bank or similar financial institution. NIL if paid to the Government.
22. The treaty provides for 15% withholding tax but the local taxation provides for 0% withholding tax.
23. NIL if paid to or is guaranteed by the Government, statutory body, the Central Bank.
24. 5% on firm royalties including films shown on TV .
25. Kyrgyzstan, Tajikistan and Uzbekistan consider themselves bound by the treaty signed with the former USSR. The rate shown are those of the treaty Cyprus / USSR.
26. Serbia and Slovenia former Yugoslavia.
27. The treaty between Cyprus and the Czech Republic still applies.
28. A rate of 5% if a dividend is paid by a Company in which the beneficial owner has invested less than Euro 150.000.
29. A rate of 15% 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.
30. 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.
31. 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.
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 individual.
33. 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.
34. This rate applies if the recipient company (Partnership is excluded) holds directry 10% of the share capital of the paying company for an uninterrupted period of at least 2 years. 5% in all other cases.
35. The provisions of the Parent-subsidiary EU directive are applicable.
36. 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 Eur 100.000.
37. 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 concering industrial, commercial or scientific experience.10% WHT will be levied in all other cases.
38. A rate of 5% if received by company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividend. 10% in all other cases.
39. A protocol to the treaty entered into force on 18 September 2015 but may apply retrospectively. 5% rate applies if the beneficial owner is a company which holds at least 10% of the capital paying the dividend. 10% in all other cases.
40. 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% or the voting power of the paying company in order to benefit from WHT rate of 5% other conditions relating to the income of the paying company need to be satisfied, otherwise a WHT rate of 15%.
41. The treaty has been signed but has not come into effect until  31st December 2018 date at which our website was updated.
42. Nil applies if the beneficial owner (other than ore partnership) holds directly at least 10% of the capital of the company paying the dividends 5% WHT rate applies for all other cases.
43. 5% if the real beneficiary is a company (not a partnership) which holds directly at least 10% of the capital, with voting power of the company who pays the dividend.
44. 0% of the real beneficiary is a Government, municipality or the Central Bank of the other state.
45. (a) 0% if the real beneficiary is a company which holds directly at least 5% of the capital of the company who pays the dividend for 365 days. (b) 0% for a recognised pension fund. (c) 15% in all other cases.
46. The treaty has been signed but has not yet entered into force as at the date of this publications.
47. 5% if the beneficial owner is a company which holds directly at least 10% of the capital of the dividend paying company 15% in all other case.
48. Nil if paid in connection with the sale in credit of an industrial, commercial or scientific equipment or any merchandise by one enterprise to another or in relation to any form of loan granted by bank.