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 |
Date of entry |
Date of Publication in the Official Gazette |
|
1 |
Austria |
20 Mar 1990 |
10 Nov 1990 |
2500 27 Apr 1990 |
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 |
26 May 1981 11 Oct 2010 |
10 Aug 1981 |
1704 17 Jul 1981 |
8 |
Egypt |
18 Dec1993 |
14 Mar1995 |
2865 11 Mar 1994 |
9 |
France |
18 Dec1981 |
1 April 1983 |
1468 9 Jul 1982 |
10 |
Germany |
9 May 1974 |
11 Oct 1977 |
1199 27 Jun 1975 |
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 |
24 April 1974 |
9 June 1983 |
1586 5 Sep 1980 4 Jun 1982 |
16 |
Kuwait |
15 Dec 1984 |
25 Sep 1986 |
2026 18 Jan 1985 |
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 |
4 Jun 1992 |
9 Jul 1993 |
2735 4 Sep1992 |
22 |
Romania |
16 Nov 1981 |
8 Nov 1982 |
1757 26 Feb 1982 |
23 |
Russia |
5 Dec1998 |
17 Aug 1999 |
3306 26 Feb 1999 |
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 |
20 Jun1974 |
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* |
29 Jun1985 |
8 Sep 1986 |
2073 23 Aug1985 |
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*** |
29 Oct 1982 |
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.