Cyprus Double Tax Treaty Network

 Cyprus Double Tax Treaty Network  : Cyprus continues to grow its Double Tax Treaty network and it has recently signed three new treaties as follows:

• Guernsey effective as of 1 January 2016 (in force)
• Switzerland effective as of 1 January 2016 (in force)
• Georgia effective as of 1 January 2017

 Cyprus has signed amendment protocols with existing treaties namely with South Africa and Ukraine and has already concluded new treaties in 2015 with Bahrain, Ethiopia and Iran, all to be entered into force upon completion of the ratification process.  The new treaties incorporate clauses for the exchange of information in line with the O.E.C.D. Model Tax convention.

Cyprus Double Tax Treaty Network: Recent Treaties

 Treaty with Guernsey  This Treaty is between Cyprus and Guernsey already into force and in affect as of 1 January 2016. It provides for zero withholding tax on interest and royalty payments as well as on dividends.  Any capital gains that arise from the sale of shares are taxable only in the seller’s country of residence.

 Treaty with Switzerland This Treaty is between Cyprus and Switzerland already into force and in affect as of 1 January 2016. It provides for zero withholding tax on dividends applying only to the receiver of income that qualifies as a pension fund or a company which holds directly at least 10% of the capital of the company paying the dividends for one year at least.  In all other 15% dividend withholding tax applies. There is also zero withholding tax on interest and royalty payments.

 Treaty with Georgia This Treaty is between Cyprus and Georgia and will be effective as of 1 January 2017 with respect to all taxes covered by the Treaty. It provides for zero withholding tax on dividends, interest and royalty payments. Capital gains derived by a resident of Cyprus or Georgia are not taxable in the country of investment with the exception of those that relate to immovable property and those from alienation of movable property of a permanent establishment. For further information and clarifications contact us so that one of our professional tax experts can advise you.