Double Taxation Treaties

*10% in the case of royalties granted for use within the Republic. 5% on film and TV rights.
**The treaty is a Covered Tax Agreement for the purposes of the Multilateral Instrument (MLI) which
has entered into force for Cyprus on 1 May 2020. Cyprus has approved the minimum standards of
BEPS Action 6 (Purpose of Covered tax Agreement), Action 7 (Prevention of Treaty Abuse) and
Action 14 (Making Dispute Resolution Mechanisms More Effective). The treaty is automatically
amended to include these provisions.
(1) 15% if received by a company controlling less than 25% of the voting power.
(2) 5% if received by a company controlling more than or equal to 10% of the capital. 15% in all other
cases.
(3) NIL if the beneficial owner is a company (other than a partnership) which holds directly at least
10% of the capital of the company paying the dividend. 15% in all other cases.
(4) 5% 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.15% in all other cases.
(5) 5% if received by a company controlling at least 10% of the voting power. 15% in all other cases.
(6) 5% if the beneficial owner is an insurance undertaking or pension funds, the Government or a
political subdivision or a local authority, the Central Bank, or a company whose shares are listed
on a registered stock exchange provided that no less than 15% of the voting shares are in free
float and which holds directly at least 15% of the dividend paying company throughout a period
of 365 days, that includes the day of the dividend payment. 15% in all other cases.
(7) 10% if received by a company controlling more than or equal to 10% of the capital. 15% in all
other cases.
(8) NIL if paid to the Government of the other State.
(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 the sale of property or the provision of services.
(11) NIL on literary, dramatic, musical, or artistic work with the exception of films used for television
programs.
(12) 5% on film royalties (except films shown on TV).
(13) 10% on literary, musical, artistic work, films, and TV royalties.
(14) NIL on literary, artistic, or scientific work including films.
(15) 5% on royalty payments in respect of any copyright of scientific work, any patent, trademark,
secret formula, process, or information concerning industrial, commercial, or scientific
experience. 10% in all other cases.
(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 by 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) 5% if the dividend is received by a company owning directly at least 25% of the capital of the
company paying divided. 10% in all other cases.
(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) 5% is applicable if the dividend is received by a company owning at least 20% of the capital of
the dividend paying company or has invested in the acquisition of shares or other rights of the
dividend paying company of at least €100.000. 10% in all other cases.
(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) 15% if dividends are paid out of income derived from immovable property by certain investment
vehicles.
(25) NIL if paid to or is guaranteed by the Government, statutory body, the Central Bank.
(26) The additional Protocol signed on 8 September 2020 between Cyprus and Russia that amends the
tax treaty is effective from 1 January 2021.
(27) The treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia still
applies.
(28) The treaty between the Republic of Cyprus and the Czechoslovak Socialist Republic still applies.
(29) NIL if the beneficial owner is a company (other than a partnership) which holds directly at least
10% of the capital of the company paying the dividends where such holding is being possessed
for an uninterrupted period of not less than one year. 5% in all other cases.
(30) NIL if the beneficial owner is an insurance undertaking or pension fund, the Government or a
political subdivision or a local authority, the Central Bank, or a bank or if it is paid in respect to
government or corporate bonds or Eurobonds, all listed on a registered stock exchange.
5% if the beneficial owner is a company whose shares are listed on a registered stock exchange
provided that no less than 15% of the voting shares are in free float and which holds directly at
least 15% of the dividend paying company throughout a period of 365 days, that includes the day
of the dividend payment.
(31) 5% if the beneficial owner has invested in the capital of the company less than the equivalent of
€150.000 at the time of the investment.
(32) NIL if paid to the Government or to a local authority, or to the Central Bank.
(33) NIL if the beneficial owner is a company (other than a partnership) which holds directly at least
10% of the capital of the company paying the dividends, where such holding is being possessed
for an uninterrupted period of no less than 12 months.
NIL if the beneficial owner is the other Contracting State or the Central Bank of that other State, or
any national agency or any other agency (including a financial institution) owned or controlled
by the Government of that other State.
NIL if the beneficial owner is a pension fund or other similar institution providing pension schemes
in which individuals may participate in order to secure retirement benefits, where such pension
fund or other similar institution is established, recognized for tax purposes, and controlled in
accordance with the laws of that other State. 15% in all other cases.
(34) NIL if the dividend is received by a company (other than a partnership) holding at least 10% of the
capital of the dividend paying company. 5% in all other cases.
(35) NIL if the beneficial owner is a company (other than a partnership) which holds directly at least
10% of the capital of the company paying the dividends, where such holding is being possessed
for an uninterrupted period of no less than 24 months. 5% in all other cases.
(36) 5% if the dividend is received by a company (other than a partnership) which controls directly at
least 10% of the voting power in the company paying the dividends. 15% in all other cases.
(37) NIL if the beneficial owner is:
a) a company (other than a partnership) the capital of which is wholly or partly divided into
shares, and which holds directly at least 10% of the capital of the company paying the dividend
for an uninterrupted period of at least one year
b) a pension fund or other similar institution recognized as such for tax purposes, or
c) the Government, a political subdivision, local authority, or central bank of one of the two
contracting states. 15% in all other cases.
(38) 5% if the beneficial owner is a company (other than a partnership) which holds directly at least
10% of the capital of the company paying the dividends. 10% in all other cases.
(39) NIL if the beneficial owner is a company which holds directly at least 10% of the capital of the
company paying the dividends. 5% in all other cases.
(40) 5% if the dividend is received by a company which holds at least 10% of the capital of the
company paying the dividends. 10% in all other cases.
(41) NIL if the beneficial owner is a company (other than a partnership). 10% in all other cases.
(42) NIL if the beneficial owner is a company (other than a partnership). 5% in all other cases.
(43) NIL if the beneficial owner is a company which holds directly or indirectly at least 25% of the
capital of the company paying the dividends. 5% in all other cases.
(44) 5% on royalties for the use of, or the right to use, industrial, commercial, or scientific equipment.
8% in all other cases.
(45) 5% if the beneficial owner is a company (other than a partnership) which holds directly at least
20% of the capital of the company paying the dividends throughout a period of 365 days, that
includes the day of payment of dividend. 10% in all other cases.
(46) 5% if the beneficial owner is a company which holds directly at least 10% of the capital of the
company paying the dividends. 15% in all other cases.
(47) NIL if the beneficial owner is the Government of the other Contracting State, a political subdivision,
a central or local authority, the Central Bank or any other financial institution wholly owned by the
Government of the other Contracting State. 10% in all other cases.
(48) NIL if the beneficial owner is:
a) a company that holds directly at least 5% of the capital of the company paying the
dividends, throughout a period of 365 days, that includes the day of the dividend payment, or
b) a recognized pension fund which is generally exempt under the Cyprus Income Tax law;
15% in all other cases.
(49) NIL if interest is derived and beneficially owned by the government, political subdivision, local
authority, or the National Bank of the other contracting State.
(50) The treaty has been signed but has not yet entered into force as at the date of this publication.
(51) NIL if paid 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.
(52) A new treaty was signed on 11 December 2023 that has not entered into force as at the date of
this publication