| (*) |
Payment of dividends and interest from Cyprus to non-residents is exempt from any withholding tax. Royalty payments arising from rights used within the Republic is subject to withholding tax at 10%, whilst royalties from film and television rights used within the Republic by a non-resident is subject to withholding tax at 5%. |
| (**) |
CIS includes Armenia , Kyrgyzstan , Tajikistan , Ukraine and Uzbekistan and excludes Kazakhstan . |
|
|
| Treaties with the following countries have reached the following stage: |
| (a) |
Negotiations in progress: Algeria, Bangladesh, Estonia, Finland, Indonesia, Latvia, Libya , Lithuania, Malaysia, Moldova, Netherlands, Slovenia, Spain, Sri Lanka and Ukraine. |
| (b) |
Negotiations will commence soon: Brazil, Gabon, Georgia, Iran, Jordan, Morocco, Portugal, Seychelles, and Vietnam. |
| (c) |
Negotiations for revision of existing agreements: Armenia, Czech Republic, Denmark, France, Germany, Ireland, Italy, Kazakhstan, Norway and Yugoslavia. |
| Notes: |
| (1) |
10% if recipient is a company with at least 25% direct share interest; 15% in all other cases |
| (2) |
10% if recipient is a company with at least 10% direct share interest; 15% in all other cases |
| (3) |
10% if recipient is a company with at least 25% direct share interest; 27% if recipient is a company with more than 25% direct or indirect share interest as long as the German corporate tax on distributed profits is lower than that on undistributed profits and the difference between the two rates is 15% or more; 15% in all other cases |
| (4) |
5% if recipient is a company with at least 25% direct share interest; 15% in all other cases |
| (5) |
Nil if received by a company which controls, directly or indirectly, at least 50% of the voting power |
| (6) |
A resident of Cyprus , other than a company which either alone or together with one or more associated companies controls directly or indirectly at least 10% of the voting power, is entitled to a tax credit in respect of the dividend. Where a resident of Cyprus is entitled to a tax credit, tax may also be charged on the aggregate of cash dividend and the tax credit at a rate not exceeding 15%. In this case any excess tax credit is repayable, Where the recipient is not entitled to a tax credit, the cash dividend is exempt from any tax. |
| (7) |
Nil if paid to the government or as an export guarantee |
| (8) |
Nil if royalties are on literary, artistic or scientific work including cinematography films and films or tapes for television or radio broadcasting. |
| (9) |
5% on cinematography films not including television films. |
| (10) |
5% on cinematography films including television films. |
| (11) |
Nil if paid, to the government or other government body, in connection with the sale on credit of any industrial, commercial or scientific equipment or in connection with the sale of any merchandise by one enterprise to another enterprise or on any loan of whatever kind granted by a bank or guaranteed by the government or other statutory body |
| (12) |
Nil if royalties are copyright or other literary, dramatic, musical or artistic work not including film or videotape royalties. |
| (13) |
5% if recipient is a company with at least 10% direct share interest; 15% in all other cases |
| (14) |
Nil if paid to the Government, political subdivision or a local authority, the National Bank or any other institution the capital of which is wholly owned by the Government or the political subdivision or the local authority or for interest on deposits not represented by bearer instruments with a banking enterprise. |
| (15) |
Nil if paid to the government, bank or financial institution |
| (16) |
Nil if shareholder is a company that holds directly at least 25% of the capital of the company paying the dividends; 15% in all other cases. |
| (17) |
15% for any patent, trade mark, design or industrial, commercial, or scientific equipment or information concerning industrial, commercial scientific experience. |
| (18) |
5% of the gross dividend where the investment in the capital of the paying company is not less than USD100,000. |
| (19) |
Nil if the recipient is a company. |
| (20) |
5% if the beneficial owner has invested not less than EUR200,000 in the share capital of the paying company. |
| (21) |
10% if it is received by any financial institution (including insurance), or is paid in connection with the sale on credit of any industrial, commercial or scientific equipment or is paid in connection with the sale on credit of any merchandise by one enterprise to another enterprise; 15% in all other cases. |
| (22) |
5% on copyright of literary, dramatic, musical, artistic, or scientific work, including software, cinematography films or films or tapes used for radio or television broadcasting; 10% on industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific expertise; 15% on patent, trade marks, design or model, plan, secret formula or process. |
| (23) |
7% if it is received by a bank or similar financial institution |
| (24) |
5% if recipient is a company owning at least 25% of the capital of the paying company |
| (25) |
Nil if it is paid to a resident of Cyprus by resident of Bulgaria and at least 25% of the capital of the Cypriot resident is owned directly or indirectly by the Bulgarian resident |
| (26) |
Has been ratified on 14 th April 2005 and will apply from year 2006. |
| (27) |
The treaty provides for 25% but local legislation states Nil. |
| (28) |
Nil if paid to the government, bank or financial institution or in relation to amounts due from sale of property or provision of services or amounts due on loans guaranteed or secured by the government. |
