Sat, 4 Sep 2010
Cyprus Accountants and Cyprus Tax Advisors
 
  About Cyprus
 
General Information
The Cyprus Economy
The Success of Cyprus as an International Business Center
  The Cyprus Tax System
 
Double Tax Treaties
EC Directives
  Cyprus Tax Planning
 
Introduction
Holding Company Structure
Financing Company Structure
Royalty Company Structure
Employment Company Structure
Trading Company Structures
Foreign Permanent Establishments
Shipping Companies
Non-resident Companies
Tax Planning for Investments in
Central and Eastern Europe
  The Cyprus Legal System
 
The Cyprus Limited Liability Company
Company Registration Procedure
International Collective Investment Schemes (ICISs)
Cyprus International Trusts
Double Tax Treaties
Notes

*Payments 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.
  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.
  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 €200.000 irrespective of the % of 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 $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 enterprise 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 the Cyprus company pays less than the normal rate of tax.
  21. The treaty provides for 25%, but the domestic rate of NIL applies since it is lower than the treaty rate.
  22. The treaty provides that the tax on the gross amount of the dividends shall not exceed that chargeable on the profits out of which the dividends are paid.
  23. 7% if paid to a bank or similar financial institution. NIL if paid to the government.
  24. The treaty provides for 15% withholding tax but the local taxation provides for 0% withholding tax.
  25. NIL if paid to or is guaranteed by the government, statutory body, the Central Bank
  26. 5% on film royalties, including films used for television programs
  27. The Treaty between the Republic of Cyprus and the United Soviet Socialist Republic still applies
  28. The Treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia still applies
  29. The Treaty between the Republic of Cyprus and the Czechoslovak Socialist Republic still applies.
 
International Double Tax Treaties with Cyprus
 
 
 
Developed by 
Website Terms & Conditons - HMI's General Terms & Conditions
Make this page your homepage Bookmark this page Email to a friend