DOUBLE TAX TREATIES

DOUBLE TAX TREATIES

Irrespective of the country of residence of the recipient or whether a relevant tax treaty exists, there is no WHT on outgoing payments from Cyprus in the form of dividends, provided the payments are made to non Cyprus tax resident shareholders (companies or individuals) or to Cyprus tax resident individuals who are not Cyprus Domiciled. Also, irrespective of the country of residence of the recipient or whether a relevant tax treaty exists, there is no WHT on interest paid from Cyprus as well as on royalties paid from Cyprus in respect of intellectual property exploited outside Cyprus to any company or individual.

Cyprus has an extensive network of countries with double tax treaties which ensure to the Cyprus tax resident companies the minimum WHT on inbound payments to Cyprus. The maximum WHT on inbound payments to Cyprus (Withholding tax abroad for income received in Cyprus) is described below:

Treaty Country Dividends Interest Royalties
Armenia 0/5 5
Austria 5/10/15 0 0
Bahrain 0 0 0
Barbados 0 0 0
Belarus 5 5 5
Belgium 10/15 0/10 0
Bosnia 10 10 10
Bulgaria 5/10 0/7 10
Canada 15 0/15 0/10
China 10 10 10
Czech Republic 0/5 0 0/10
Denmark 0/15 0 0
Egypt 15 15 10
Ethipia 5 5 5
Estonia 0 0 0
Finland 5/15 0 0
France 10/15 0/10 0/5
Germany 5/15 0 0
Greece 25 10 0/5
Guernsey 0 0 0
Hungary 5/15 0/10 0
Iceland 5/10 0 5
India 10 0/10 10
Iran 5/10 5 6
Ireland 5/10 0 5
Ireland 0 0 0/5
Italy 15 10 0
Jersey 0 0 0
Kuwait 0 0 5
Latvia 0/10 0/10 0/5
Lebanon 5 5 0
Lithuania 0/5 0 5
Malta 0 10 10
Mauritius 0 0 0
Montenegro 10 10 10
Moldova 5/10 5 5
Norway 0/15 0 0
Poland 0/5 0/5 5
Portugal 10 10 10
Qatar 0 0 5
Romania 10 0/10 0/5
Russia 5/10 0 0
San Marino 0 0 0
Serbia 10 10 10
Seychelles 0 0 5
Singapore 0 0/7/10 10
Slovak Republic 10 0/10 0/5
Slovenia 5 5 5
South Africa 5/10 0 0
Spain 0/5 0 0
Sweden 5/15 0/10 0
Syria 0/15 0/10 10/15
Thailand 10 10/15 5/10/15
Ukraine 5/15 2 5/10
United Arab Emirates 0 0 0
United Kingdom 0/15 10 0/5
United States 5/15 0/10 0

"A combination of tax and non-tax incentives helped Cyprus to be established as an International Business Centre.
Your first option is to relocate your business in Cyprus and use Cyprus for your operations either in Europe or Worldwide. The second general option is to include a Cyprus Company in your structure to get advantage of the tax incentives and its wide network of DDT.
Below, we present the main features of Cyprus Companies with different activities. We will be happy to provide you with our comprehensive advice on tax planning solutions, on request, once we have information about your existing structure, your activities and your needs."