Cyprus double tax treaties concluded with the rest of the world
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.
The actual withholding tax rate charged may be lower/eliminated based on each paying country’s domestic law provisions or in the case of an EU country by the EU parent-subsidiary, Interest, and Royalty Directive
Cyprus does not impose withholding tax on dividends, interest, and royalties paid to non-residents of Cyprus, except in the case of royalties acquired from rights used in Cyprus, which are subject to a withholding tax of 10% (5% in the case of motion pictures). . This can be reduced or eliminated by double taxation agreements entered into by Cyprus or by the EU Interest and Royalty Directive.
As of 31 December 2022, Cyprus applies a withholding tax of 17% on dividends paid by unlisted companies, 30% on passive interest payments (excluding payments from natural persons), and 10% on royalty and similar payments (excluding payments from natural persons) if the recipient of the payment is a company in a jurisdiction on the EU’s list of non-cooperative tax jurisdictions (commonly referred to as the EU “blacklist”).
CYPRUS DOUBLE TAX TREATIES WITHHOLDING TAX RATES
| Treaty country | Dividends received in Cyprus | Interest received in Cyprus | Royalties received in Cyprus | Dividends paid from Cyprus (1) | Interest paid from Cyprus (1) | Royalties paid from/ not used in Cyprus (1) | Royalties paid from/ used in Cyprus (1) |
| Andorra | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Armenia | 0(24) | 5 | 5 | 0 | 0 | 0 | 5 |
| Austria | 10 | 0 | 0 | 0 | 0 | 0 | 0 |
| Azerbaijan (36) | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Bahrain | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Bailiwick of Guernsey | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Barbados (31) | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Belarus | 5/10/15(14) | 5 | 5 | 0 | 0 | 0 | 5 |
| Belgium | 10/15 (5) | 0/10(4&39) | 0 | 0 | 0 | 0 | 0 |
| Bosnia (25),(44) | 10 | 10 | 10 | 0 | 0 | 0 | 5/10 (55) |
| Bulgaria | 5/10(20) | 0/7(4&23) | 10(23) | 0 | 0 | 0 | 5/10 (55) |
| Canada | 15 | 0/15(3) | 0/10(12) | 0 | 0 | 0 | 0/5/10 (55, 56) |
| China | 10 | 10 | 10 | 0 | 0 | 0 | 5/10 (55) |
| Czech Republic | 0/5(27) | 0 | 0/10(28) | 0 | 0 | 0 | 0/10 (57) |
| Denmark (29) | 0/15(40) | 0 | 0 | 0 | 0 | 0 | 0 |
| Egypt (43) | 5/10(67) | 10 | 10 | 0 | 0 | 0 | 5/10 (55) |
| Estonia | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Ethiopia | 5 | 5 | 5 | 0 | 0 | 0 | 5 |
| Finland | 5/15(33) | 0 | 0 | 0 | 0 | 0 | 0 |
| France | 10/15(6) | 10(7) | 0(2) | 0 | 0 | 0 | 0/5 (55) |
| Georgia | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Germany | 5/15(6) | 0 | 0 | 0 | 0 | 0 | 0 |
| Greece | 25(8) | 10 | 0/5(9) | 0 | 0 | 0 | 0/5 (55) |
| Guernsey | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Hungary | 5/15(5) | 0/10(4) | 0 | 0 | 0 | 0 | 0 |
| Iceland | 5/10(34) | 0 | 5 | 0 | 0 | 0 | 5 |
| India (47) | 10(6) | 0/10(7) | 10(11) | 0 | 0 | 0 | 5/10 (55) |
| Iran | 5/10(44) | 5 (4) | 6 | 0 | 0 | 0 | 5/6 (55) |
| Ireland | 0 | 0 | 0/5(9) | 0 | 0 | 0 | 0/5 (55) |
| Italy | 15 | 10 | 0 | 0 | 0 | 0 | 0 |
| Jersey | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Jordan (63)(65) | 5/10(66) | 5 | 5/7 | 0 | 0 | 0 | 5/7(64) |
| Kazakhstan (43) | 5/15(33) | 10(51) | 10 | 0 | 0 | 0 | 5/10 (55) |
| Kuwait | 0 | 0 | 5 | 0 | 0 | 0 | 5 |
| Kyrgyzstan (36) | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Latvia (31) | 0/10 (47) | 0/10 (48) | 0/5 (49) | 0 | 0 | 0 | 0/5 (58) |
| Lebanon | 5 | 5 | 0 | 0 | 0 | 0 | 0 |
| Lithuania | 0/5(37) | 0 | 0/(41) | 0 | 0 | 0 | 5 |
| Luxembourg | 0/5(37) | 0 | 0 | 0 | 0 | 0 | 0 |
| Malta | 0 | 5 | 10 | 0 | 0 | 0 | 5/10 (55) |
| Mauritius | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Moldova | 10(7) | 5 | 5 | 0 | 0 | 0 | 5 |
| Montenegro (25),(44) | 10 | 10 | 10 | 0 | 0 | 0 | 5/10 (55) |
| Norway | 5(20) | 0 | 0 | 0 | 0 | 0 | 0 |
| Poland | 0/5(16) | 0/5/(41) | 5 | 0 | 0 | 0 | 5 |
| Portugal | 10 | 10 | 10 | 0 | 0 | 0 | 5/10 (55) |
| Qatar | 0 | 0 | 5 | 0 | 0 | 0 | 5 |
| Romania | 10 | 0/10(4) | 0/55(13) | 0 | 0 | 0 | 0/5 (59) |
| Russia | 5/15(17) | 0/15(51) | 0 | 0 | 0 | 0 | 0 |
| San Marino | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| Saudi Arabia | 0/5(52) | 0 | 5/8(53) | 0 | 0 | 0 | 5/8 (60) |
| Serbia (25) | 10 | 10 | 10 | 0 | 0 | 0 | 5/10 (55) |
| Seychelles | 0 | 0 | 5 | 0 | 0 | 0 | 5 |
| Singapore | 0 | 0/7/10(4)(18) | 10 | 0 | 0 | 0 | 5/10 (55) |
| Slovakia (30) | 10 | 10(4) | 5(13) | 0 | 0 | 0 | 0/5 (59) |
| Slovenia | 5 | 5 | 5 | 0 | 0 | 0 | 5 |
| South Africa | 5/10(54) | 0 | 0 | 0 | 0 | 0 | 0 |
| Spain | 0/5(35) | 0 | 0 | 0 | 0 | 0 | 0 |
| Sweden | 5/15(5) | 0/10(4) | 0 | 0 | 0 | 0 | 0 |
| Swiss Confederation | 0/15(40) | 0 | 0 | 0 | 0 | 0 | 0 |
| Syria | 0/15(5) | 0/10(4) | 10/15(19) | 0 | 0 | 0 | 5/10 (55) |
| Tajikistan (36) | 0 | 0 | 0 | 0 | 0 | 0 | 0/5 (59) |
| Thailand | 10 | 10/15(21) | 5/10/15(22) | 0 | 0 | 0 | 5/10 (61) |
| Ukraine (46) | 5/10(32) | 5 | 5/10(42) | 0 | 0 | 0 | 5/10 (62) |
| United Arab Emirates | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
| United Kingdom | 0/15(10) | 0 | 0 | 0 | 0 | 0 | 0 |
| United States | 5/15(26) | 0/10(7) | 0 | 0 | 0 | 0 | 0 |
| Uzbekistan (36) | 0 | 0 | 0 | 0 | 0 | 0 | 0 |
Cyprus double tax treaties notes:
- Cyprus does not impose withholding tax on dividends, interest, and royalties paid to non-Cyprus residents, except in the case of royalties earned and used in Cyprus, which are subject to a withholding of 10% (5% for films). As of 31 December 2022, Cyprus will apply to withhold tax for the payment of dividends (17%), interest (30%), and royalties (10%) in countries of the EU list with non-cooperative tax jurisdictions on tax issues (commonly referred to as the EU “blacklist”).
- A 5% withholding tax applies only to television and film rights.
- A 0% withholding tax applies if it is paid to a Government or for an export guarantee.
- Α 0% withholding tax if paid to the government/Central Bank/ Public Authority of the other state
- 15% withholding tax 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.
- 15% withholding tax 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.
- A 0% withholding tax applies if it is paid to a Government, a financial institution, or a bank of the contracting state.
- The double tax treaty between Cyprus and Greece provides 25% withholding tax but according to the legislation of Greece 10% tax is withheld as of 1/1/2009.
- A 5% withholding tax applies only to film rights.
- The double tax treaty between Cyprus and the United Kingdom provides a 15% withholding tax. Νo 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.
- A 10% withholding tax applies for payments of a technical, administrative, or advisory nature.
- 0% withholding tax applies on theatrical, musical, literary, or any other artistic work.
- 0% withholding tax applies for patents, production processes, or any royalties arising from scientific research.
- A withholding tax rate of 5% applies in cases of investments not less than €200.000. Dividends are subject to a 15% withholding tax reduced to 10% if the recipient company controls more than 25% of the company’s share capital.
- 0% withholding tax 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.
- 0% withholding tax 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% withholding tax applies in all other cases.
- A 5% withholding tax applies if the beneficial owner of the company is an insurance undertaking or pension fund, or if the beneficial owner is a company whose shares are listed on a recognised stock exchange provided not less than 15% of the voting shares of the company are in free float and which holds directly 15% of the capital of the company paying the dividends throughout a 365 period that includes the day of the payment of dividends, or if the beneficial owner of the dividends is the government of that contracting state
- A 7% withholding tax applies if it is paid to a bank or a relevant financial institution.
- A 10% withholding tax applies to artistic, scientific, and literary work.
- A 10% withholding tax applies if it is received by a company holding less than 25% of the share capital of the company issuing the dividend.
- A 10% withholding tax applies on interest paid to a financial institution or on interest paid in connection with commercial, industrial, or even scientific equipment
- A 10% withholding tax applies on royalties in connection with commercial, industrial, or even scientific equipment and increases to 15% for patents, production processes, or any other royalties arising from scientific research.
- The withholding tax 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.
- A rate of 5% withholding tax applies if a dividend is paid by a company in which the beneficial owner has invested less than €150.000.
- The provisions of the double tax treaty between Cyprus and the former Socialist Federal Republic of Yugoslavia still Bosnia also apply this provision.
- A 5% withholding tax applies if it is received by a company that controls at least 10% of the voting rights. If the company controls at least 10% of the voting power of the paying company in order to benefit from the withholding tax rate of 5% other conditions relating to the income of the paying company need to be satisfied otherwise a withholding tax of 15% applies.
- Withholding tax 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 withholding tax of 5% applies.
- 10% withholding tax 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.
- Under the double tax treaty provisions with Cyprus, 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 tax applies.
- The double tax treaty between Cyprus and the Czechoslovak Socialist Republic still applies.
- The double tax treaty is effective from 1 January 2018.
- A 15% withholding tax applies if the investment is less than €000 and lower than 20% of the company’s share capital.
- A 5% withholding tax 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 a 15% withholding tax
- A 5% withholding tax applies if the recipient is a company that owns at least 10 % of the company distributing the dividends. In all other cases, a withholding tax of 10% applies.
- 0% withholding tax applies if the dividend is received by a company holding at least 10% of the issued share capital. 5% applies in all other cases.
- The double tax treaty between Cyprus and the United Soviet Socialist Republic still applies.
- 0% withholding tax applies if the beneficial owner is a company that holds directly at least 10% of the capital of the company paying the dividends. A 5% withholding tax applies in all other cases.
- 0% withholding tax applies if the beneficial owner is a company that holds directly at least 10% of the capital of the company paying the dividends, where such holding is being possessed for an interrupted period of 24 months. A 5% withholding tax applies in all other cases.
- Nil withholding tax is applied on interests derived from deposits in financial institutions.
- 0% withholding tax 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% withholding tax applies in all other cases.
- Nil withholding tax applies if the recipient company holds directly 10% of the share capital of the paying company for an uninterrupted period of 2 years. A 5% withholding tax applies in all other cases
- A 5% withholding tax applies for royalties in respect of copyrights of scientific work, patents, trademarks, secret formulas, production processes, or information relating to industrial, commercial, or scientific experience. 10% withholding tax applies in all other cases.
- A withholding tax rate of 5% if the beneficial owner is a company holding at least 20% of the capital of the company paying the dividends throughout a 365-period including the date of the payment of the dividend. In all other cases, a 10% withholding tax applies
- A 5% withholding tax applies if the recipient is a company that owns at least 25 % of the company distributing the dividends. In all other cases a 10% withholding tax
- A new double tax treaty concluded and effective
- New protocol as of 1 January 2020.
- 0% withholding tax applies if it is received by a company (other than a partnership). 10% withholding tax applies in all other cases.
- 0% withholding tax applies if it is received by a company (other than a partnership) or by the government of any of the two contracting states. 10% withholding tax applies in all other cases.
- 0% withholding tax applies if it is received by a company (other than a partnership). A 5% withholding tax applies in all other cases.
- Other than the double tax treaties which are presently in force, the conclusion of various other agreements is pending. These agreements are currently under negotiation.
- 0% withholding tax applies if the beneficial owner is an insurance undertaking or a pension fund, the government of the contracting state, or a bank. 0% also applies to interest paid in respect of securities that are listed on a recognised stock exchange. 15% withholding tax in all other cases
- 0% withholding tax applies to dividends if the recipient is a company that directly or indirectly holds at least 25% of the capital of the payer company. 5% withholding tax in all other cases
- 5% withholding tax applies on payments for the use of, or the right to use industrial, commercial, and scientific equipment. 8% withholding tax in all other cases
- 5% withholding tax applies if the beneficial owner is a company that holds at least 10% of the capital of the company paying the dividend. 10% withholding tax in all other cases
- 5% withholding tax applies on film royalties
- 0% on literary, dramatic, musical, or artistic work (excluding motion picture films and works on film or videotape for use in connection with television).
- 10% withholding tax applies for a patent, trademark, design or model, plan, secret formula or process, computer software or industrial, commercial, or scientific equipment, or for information concerning the industrial, commercial, or scientific experience.
- 10% withholding tax applies for a patent, trademark, design or model, plan, secret formula or process, computer software or industrial, commercial, or scientific equipment, or for information concerning the industrial, commercial, or scientific experience.
- A 5% withholding tax rate applies for patents, trademarks, designs or models, plans, secret formulas, or processes, or any industrial, commercial, or scientific equipment, or for information concerning the industrial, commercial, or scientific experience.
- A 5% withholding tax rate applies on royalties for the use of, or the right to use, industrial, commercial or scientific equipment and on royalties for cinematographic films including films and videotape for television. A rate of 8% applies in all other cases.
- A 5% withholding tax rate applies for any copyright of literary, dramatic, musical, artistic, or scientific work.
- A 5% withholding tax rate applies on payment of royalties in respect of any copyright of scientific work, any patent, trademark, secret formula, process, or information concerning industrial, commercial, or scientific experience and cinematographic films.
- 15% if received from a company (excluding partnership) holding less than 10% of the capital of the paying company and in all cases if received from an individual.
- Nil if paid to a government, bank, or financial institution.
- The treaty is effective as of 1 January 2023.
- A 5% withholding rate applies if the beneficial owner is a company that directly owns at least 10% of the paying company’s capital. In all other cases, a 10% withholding rate applies.
- Α 5% if the beneficial owner is a company (other than a partnership) that directly owns at least 20% of the capital of the company paying the dividends during a period of 365 days that includes the day the dividend is paid. In all other cases, a 10% withholding rate applies.
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