Cyprus Double Taxation Treaties: Tax Benefits for Foreign Investors Which are the main benefits of the Cyprus Double Tax Treaty to the owner of a Cyprus company? For an international businessman planning his tax correctly is a key element to his success in increasing his profits and to overcome the competition. Cyprus has for years now in fact since before 1956 realized that . It has since signed over 42 Double Taxation Treaties with third countries. Some of those DTTs are indeed very favorable. Cyprus in an intensive race of incessant efforts has managed to sign over 42 Double Tax Treaties with many third countries all over the world. This makes the Cyprus Company very attractive for tax planning for the serious and dedicated international businessman.

More than 200.000 companies are registered till now and the number is growing steadily. Combined with the a low corporate tax of 12.5% and the equally very important 0% tax on dividends paid out and coupled with a liberal Cyprus Tax legislation, Cyprus is a jurisdiction which offers many and rich tax incentives to the international tax Entrepreneur. The main target of the DTTs is the avoidance of taxing twice income earned in any of these countries. Because of the provisions of these agreements, a credit is allowed against the tax which would otherwise be levied by the country in which the taxpayer resides.

A Double Taxation Treaty also clarifies the scope of the taxing rights of each contracting country, allowing thus international trade to be transacted with a degree of certainty and stability. This is why Tax Treaties for the avoidance of double taxation are important tools for international tax planning. They are also a substantive attraction to international investors, for any jurisdiction which has entered into such agreements. Further Double Taxation Treaties are of key importance for international business, as they encourage investments from one country to another.
Let be noted that Double Taxation Treaties are useful tools for both Income Tax (personal tax) and Corporate Tax,thus in their own particular way providing relief in two principal and very important sectors of international business. The first facet of this tool allows the tax levied in one country to be credited against tax payable in the other contracting country with respect to the same income. the second facet is that the Treaties exempt certain classes of revenue from being taxed either in one or the other contracting country.

Generally treaties create exemptions which provide that the legal entity operating in one territory will not be liable to tax on profits made in the other territory unless it has a permanent establishment in that other territory. Most of the treaties determine that the country where the taxpayer resides is the appropriate territory where his total revenue will be assessed. Then relief is given for certain types of revenues which are more appropriately taxed in the territory where they arise.

See Below the Double Tax Treaties of Cyprus

State

Date of
Signature
Treaty/Protocol/
Note

Date of entry
into force

Date of Publication in the Official Gazette
of the Republic
(Number and date)

1

Austria
(new agreement)

20 Mar 1990
21 May 2012

10 Nov 1990

2500 27 Apr 1990
4160 5 Oct 2012

2

Bulgaria

30 Oct 2000

3 Jan 2001

3461 30 Dec 2000

3

Belarus

29 May 1998

12 Feb 1999

3273 9 Oct 1998

4

Belgium

14 May 1996

8 Dec1999

3365 19 Nov 1999

5

Canada

2 May 1984

3 Sep1985

2053 31 May 1985

6

China

25 Oct1990

5 Oct 1991

2578 22 Feb 1991

7

Denmark
Treaty
Notes
New Agreem.*

26 May 1981

      11 Oct 2010

10 Aug 1981
10 Apr 1982
7 Sept 2011

1704 17 Jul 1981
2034 24 Sep 1982
4145 5 Sept 2011

8

Egypt

18 Dec1993

14 Mar1995

2865 11 Mar 1994

9

France

18 Dec1981

1 April 1983

1468 9 Jul 1982

10

Germany
new Agreement

9 May 1974
18 Febr 2011

11 Oct 1977
16 Dec 2011

1199 27 Jun 1975
4145 5 Sept 2011

11

Greece

30 Mar1968

16 Jan 1969

651 10 May 1968

12

Hungary

30 Nov1981

24 Nov 1982

862 7 May 1982

13

India

13 Jun 1994

21 Dec 1994

2921 4 Nov 1994

14

Ireland

24 Sep1968

12 Jul1970

726 19 May 1969

15

Italy
Treaty
Protocol
(Additional Protocol)

24 April 1974
7 Oct 1980
4 Jun 2009

9 June 1983

1586 5 Sep 1980

   4 Jun 1982
4125 4 Jun 2010

16

Kuwait
(New Agreement)

15 Dec 1984
5 Oct 2010

25 Sep 1986

2026 18 Jan 1985
4145 5 Sept 2011

17

Lebanon

18 Feb 2003

14 Apr 2005

3976 8 Apr 2005

18

Malta

22 Oct 1993

11 Aug 1994

2860 25 Feb 1994

19

Mauritius

21 Jan 2000

12 Jun 2000

3410 2 Jun 2000

20

Norway

2 May 1951

1 Jan 1955

11 Jun 1956

21

Poland
(new agreement)

4 Jun 1992
22 Mar. 2012

9 Jul 1993

2735 4 Sep1992
4156 30 Mar. 2012

22

Romania

16 Nov 1981

8 Nov 1982

1757 26 Feb 1982

23

Russia
(Amendment Protocol)

5 Dec1998
7 Oct 2010

17 Aug 1999
2 April 2012

3306 26 Feb 1999
4145 5 Sept 2011

24

South Africa

26 Nov 1997

8 Dec1998

3214 16 Jan 1998

25

Sweden

22 Oct 1988

14 Nov1989

2377 20 Jan 1989

26

Syria

15 Mar 1992

22 Feb 1995

2863 4 Mar 1994

27

Singapore

24 Nov 2000

8 Feb 2001

3641 30 Dec 2000

28

Thailand

27 Oct 1998

4 April 2000

3394 17 Mar 2000

29

United Kingdom
Treaty
Protocol

20 Jun1974
2 Apr 1980

1 Nov1974

1107 5 Jul 1974

30

USA

19 Mar 1984

31 Dec 1985

1944 4 April 1984

31

Serbia*

29 Jun1985

8 Sep1986

2073 23 Aug 1985

32

Montenegro*

29 Jun1985

8 Sep 1986

2073 23 Aug1985

33

Slovenia*
(New Agreement)

29 Jun1985
12 Oct 2010

8 Sep 1986
14 Sept 2011

2073 23 Aug1985
4145 5 Sept 2011

34

Slovakia**

15 April 1980

30 Dec 1980

1599 3 May1980

35

Czech Republic

(new agreement)

15 April1980

     28 April 2009

30 Dec 1980

26 Nov 2009

1599 3 May1980

     4114 13 Nov 2009

36

Azerbaijan***

29 Oct 1982

26 Aug 1983

26 Nov 1982

37

Armenia

17 Jan 2011

19 Sept 2011

4145 5 Sept 2011

38

Kyrgyzstan***

29 Oct 1982

26 Aug 1983

26 Nov 1982

39

Moldova

28 Jan 2008

03 Sept 2008

4098 29 Aug 2008

40

Ajikistan***

29 Oct 1982

26 Aug 1983

26 Nov 1982

41

Uzbekistan***

29 Oct 1982

26 Aug 1983

26 Nov 1982

42

Ukraine***
(new agreement)

29 Oct 1982
8 Nov 2012

26 Aug 1983

26 Nov 1982

43

Seychelles

28 Jun 2006

  27 Oct 2006

25 Oct 2006

44

San Marino

27 April 2007

18 July 2007

4088 13 July 2007

45

Quatar

11 Nov 2008

20 Mar 2009

4099 14 Nov 2008

46

United Arab Emirates

      27 Feb 2011

4145 5 Sept 2011

47       Estonia

15 Oct 2012

48

Finland

15 Nov 2012

49

Portugal

19 Nov 2012

If you have problem accessing the texts of any Double Taxation Treaty, please get in touch with us and our personnel will be only too glad to send it to you in English.

Notes

* 7 Denmark – The existing Convention shall cease to have effect as from 1.1.2012.

* The treaty between Cyprus and the Socialist Federal Republic of Yugoslavia is still in force.

** The treaty between Cyprus and the Czechoslovak Socialist Republic is still in force.

 

 

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