Double tax treaties

Notes

1

 

No withholding tax is imposed in Cyprus upon payment of dividends, interests and royalties to non-residents of Cyprus.

2

 

10% when the royalties are used within the Republic.

3

 

5% on film and TV royalties. 

4

 

Nil if paid to a Government or for export guarantee.

5

 

Nil on literary, dramatic, musical or artistic work.

6

 

Nil if paid to the Government of the other state.

7

 

This rate applies for patents, trademarks, designs or models, plans, secret formulate or process, or any industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.

8

 

15% if received by a company controlling less than 25% of the voting power.

9

 

15% if received by a company controlling less than 10% of the voting power.

10

 

Nil if paid to a Government, bank or financial institution.

11

 

The treaty provides for withholding taxes on dividends but Greece does not impose any withholding tax in accordance with its own legislation.

12

 

5% on film royalties.

13

 

5% if received by a company controlling less than 50% of the voting power.

14

 

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.

15

 

10% for payments of a technical, managerial or consulting nature.

16

 

Treaty rate 15% therefore restricted to Cyprus legislation rate.

17

 

10% if dividends paid by a company in which the beneficial owner has invested less than US$100,000.

18

 

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.

19

 

No withholding tax for interest on deposits with banking institutions.

20

 

Armenia, Azerbaijan, Kirghizstan, Moldova, Tadzhikistan, Uzbekistan and Ukraine apply the USSR/Cyprus treaty.

21

 

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.

22

 

This rate applies for any copyright of literary, dramatic, musical, artistic or scientific work.  A 10% rate applies for industrial, commercial or scientific equipment.  A 15% rate applies for patents, trade marks, designs or models, plans, secret formulate or processes.

23

 

This rate applies to companies holding directly at least 25% of the share capital of the company paying the dividends. In all other cases the withholding tax is 10%.

24

 

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.

25

 

7% if paid to bank or financial institution.

26

 

Slovenia and Serbia/Montenegro apply the Yugoslavia/Cyprus treaty.

 

 

 
 







 

 

 
 
 

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