Double Tax Agreements

Tax Treatment of Dividends, Interest and Royalties
Note under Cyprus domestic legislation there is no withholding tax on dividends and interest paid to non-residents of Cyprus at all times thus the treaty rates shown below are NOT applicable. 
 
 Paid from Cyprus
 Received in Cyprus
Country
Dividends
%
Interest
%
Royalties
%
Dividends
%
Interest
%
Royalties
%
Non-treaty countries
nil
nil
nil (2)
 
 
 
Armenia
nil(30)
5
5
nil(30)
5
5
Austria
10
nil
Nil
10
nil
nil
Belarus
5(17)
5
5
5(17)
5
5
Belgium
10(8)
10(6,18)
nil
10(8)
10(6,18)
nil
Bulgaria
5(22)
7(6)
10
5(22)
7 (6, 23)
10 (23)
Canada
15
15(4)
10(5)
15
15(4}
10(5)
China
10
10
10
10
10
10
Czech Republic
nil(28)
nil
nil(29)
nil(28)
nil
nil(29)
Denmark
nil(6,32)
nil
nil
Nil (6,32)
nil
nil
Egypt
15
15
10
15
15
10
Estonia
nil
nil
nil
nil
nil
Nil
Finland
5(35)
nil
nil
5(35)
nil
nil
France
nil
10(10)
nil (3)
10(36)
10(10)
nil(3)
Germany
5(36)
nil
nil
5(36)
nil
nil
Greece
25
10
nil (11)
25(11)
10
nil (11)
Hungary
nil
10(6)
nil
5(8)
10(6)
nil
India
10(37)
10(10)
10(15)
10(37)
10(10)
15(14)
Ireland
nil
nil
nil (11)
nil
nil
nil (11)
Italy
nil
10
nil
15
10
nil
Kuwait
nil
nil
5
nil
nil
5
Lebanon
5
5
nil
5
5
nil
Malta
15
10
10
nil
10
10
Mauritius
nil
nil
nil
nil
nil
nil
Moldova
5(26)
5
5
5(26)
5
5
Montenegro (25)
10
10
10
10
10
10
Norway
nil
nil
nil
nil (12)
nil
nil
Poland
nil(34)
5(6)
5
nil(34)
5(6)
5
Portugal
10
10
10
10
10
10
Qatar
nil
Nil
5(27)
0
0
5
Romania
10
10(6)
5(7)
10
10(6)
5(7)
Russia
5(16)
Nil
nil
5(16)
nil
nil
San Marino
nil
Nil
nil
nil
nil
nil
Serbia (25)
10
10
10
10
10
10
Seychelles
nil
nil
5
nil
nil
5
Singapore
nil
10(6,24)
10
nil
10(6,24)
10
Slovakia
10
10 (6)
5(7)
10
10(6)
5(7)
Slovenia
5(31)
5
5
5(31)
5
5
South Africa
nil
nil
nil
nil
nil
nil
Spain(38)
nil(39)
nil
nil
nil(39)
nil
nil
Sweden
5 (8)
10 (6)
nil
5(B)
10(6)
nil
Syria
nil (8)
10 (4)
10
nil (8)
10 (4)
10
Thailand
10
15(20}
5(21)
10
15(20)
5(21)
Ukraine
5(19)
2
5(33)
5(19)
2
5(33)
United Kingdom
nil
10
nil(3)
15(13)
10
nil(3)
United States
nil
10(10)
nil
5(9)
10(10)
nil


Explanatory Notes:
 
1.     Under Cyprus legislation there is never any WHT on dividends and interest paid to non-residents of Cyprus.
 
2.     Royalties earned on rights used within Cyprus are subject to WHT of 10%.
 
3.     A rate of 5% on film and TV royalties.
 
4.     Nil if paid to a government/Central Bank/ Public Authority or for export guarantee.
 
5.     Nil on literary, dramatic, musical, or artistic work.
 
6.     Nil if paid to the government/Central Bank/ Public Authority of the other state.
 
7.  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.
 
8.     A rate of 15% if received by a company holding less than 25% of the share capital of the paying company and in all cases if received by an individual.
 
9.    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% 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%.
 
10. Nil if paid to a government, bank, or financial institution.
 
11. A rate of 5% on film royalties.
 
12. A rate of 5% if received by a company controlling less than 50% of the voting power and in all cases if received by an individual.
 
13. 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.
 
14. A rate of 10% for payments of a technical, managerial, or consulting nature.
 
15. Treaty rate is 15%. However, the maximum WHT per Cyprus tax legislation is 10% .
 
16. A rate of 10% on dividend if paid by a company in which the beneficial owner has invested less than EUR100.000 in the share capital of the company paying the dividend.
 
17. If investment is less than EUR 200,000, dividends are subject to 15% WHT which is reduced to 10% if the recipient company controls 25% or more of the paying company.
 
18. No WHT for interest on deposits with banking institutions.
 
19. 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.
 
20. A rate of 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.
 
21. 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, trademarks, designs or models, plans, secret formulas, or processes.
 
22. 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 WHT is 10%.
 
23. 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.
 
24. A rate of 7% if paid to a bank or financial institution.
 
25. Serbia, and Montenegro apply the Yugoslavia/Cyprus treaty.
 
26. This rate applies if received by a company (excluding partnerships) that holds directly 25% of the shares. A rate of 10% applies in all other cases.
 
27. 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, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial, or scientific experience.
 
28. 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.
 
29. 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.
 
30. A rate of 5% if a dividend is paid by a company in which the beneficial owner has invested less than EUR 150.000.
 
31. The provisions of the Parent-Subsidiary EU directive are applicable.
 
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 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.
 
34. 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.
 
35. 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.
 
36. 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.
 
37. 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.
 
38. 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.
 
39. 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