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DTT Table (Received in Cyprus) - updated Jun '17

DTT Table (Paid from Cyprus) - updated Jun '17

1) Received in Cyprus

*Important Notes:

*Possible use can be made of EU Directives to eliminate or reduce these rates - so rendering the treaty benefits is redundant. Treaties will be used where EU Directives are not applicable.

Received in Cyprus*

Country	Dividends (%)	Interest (%)	Royalties (%)
Armenia	0/5 if the beneficial owner has invested in the capital of the Company less than equivalent of €150.000 at the time of the investment	5/0 if paid to the Government or to a local authority, or to the Central Bank	5
Austria	10	0	0
Bahrain (The treaty is effective from 01/01/2017)	0	0	0
Belarus	5/10/15 (5 if amount invested > 200.000 EURO irrespective of % of votes / if less than EUR 200.000 then 15% reduced to 10% if at least 25% of share cap. owned)	5	5
Belgium	10 / 15 if received by a company holding <25% of votes and in all cases if received by an individual	10 / 0 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 sale of property or the provision of services	0
Bosnia The treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia still applies	10	10	10
Bulgaria	10/5 if received by a company owning at least 25% of share cap	7/0 if paid to or is guaranteed by the Government, statutory body, the Central Bank.	10 / does not apply if at least 25% of cap. of Cypriot resident owned directly or indirectly by Bulgarian resident paying the royalties and the Cyprus company is subject to a preferential tax rate
Canada	15	15 / 0if paid to the Government or for export guarantee	10 / 0 on literary, dramatic musical or artistic work with the exception of films used for television programs
China	10	10	10
Czech Republic	5/0 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.	0	10
Denmark	15/0 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 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 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	0	0
Egypt	15	15	10
Estonia	0	0	0
Finland	5/15 if received by a company holding <10% of votes and in all cases if received by an individual	0	0
France	5/15 if received by company (other than a partnership) holding < 10% of votes and in all cases if received by an individual	10 / 0 if paid to Government or in connection to 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 guaranteed from Government or other State body	0/5 on films including films used for television programs
Georgia (The treaty is effective from 01/01/2017)	0	0	0
Germany	5/15 if received by company holding < 10% of votes and in all cases if received by an individual	0	0
Greece	25	10	0 / 5 on film royalties (except films shown on TV)
Guernsey (The treaty is effective from 01/01/2016	0	0	0
Hungary	5/15 if received by a company holding <25% of votes and in all cases if received by an individual	10/0 if paid to public body or financial institution	0
Iceland	10/5 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	0	5
India	10/ prior to 1 April 2017 the rate is 15 if received by a company holding <10% of votes	10/ 0 if paid to a government or any other institution agreed upon between the 2 states. Prior to 1 April 2017, 0 also applies if paid to a bank or financial institution	10 / also applicable on payment of technical fees, management fees and consultancy fees. Prior to 1 April 2017, a rate of 15% applies on royalties
Ireland	0	0	0 / 5 on film royalties (except films shown on TV)
Iran	10 / 5 if received by a company that holds at least 25% of the capital of the paying company	5	6
Italy	15	10	0
Jersey (The treaty is effective from 01/01/2018)	0	0	0
Kuwait	0	0	5
Latvia	0 if payer is a company that is resident in Latvia and the beneficial owner of the income is a company (other than partnership) that is resident in Cyprus / 10 for all other cases	0 if payer is a company that is resident in Latvia and the beneficial owner of the income is a company (other than partnership) that is resident in Cyprus / 10 for all other cases (except for certain governmental interest)	0 if payer is a company that is resident in Latvia and the beneficial owner of the income is a company (other than partnership) that is resident in Cyprus / 5 for all other cases
Lebanon	5	5 / 0 if paid to public body	0
Lithuania	0/5 if the beneficial owner is a company (other than a partnership) which holds less than 10% of the capital of the company paying the dividends and in all cases if received by an individual	0	5
Malta	0 The treaty provides that the tax on gross dividends shall not exceed that chargeable on the profits out of which the dividend is paid	10/ 0 if paid to public body or financial institution	10
Mauritius	0	0	0
Moldova	10/5 if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends	5	5
Montenegro The treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia applies	10	10	10
Norway	15/0 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	0	0
Poland	5/0 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/ 0 if paid to public body or financial institution	5
Portugal	10	10	10
Qatar	0	0	5
Romania	10	10/ 0 if paid to public body or financial institution	5 /
Russia	5 / 10 if received by a company which has invested < $100.000	0	0
San Marino	0	0	0
Serbia The treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia still applies	10	10	10
Seychelles	0	0	5
Singapore	0	10 / 7 if paid to a Bank or similar financial institution / 0 if to the Government	10
Slovakia The treaty between the Republic of Cyprus and the Czechoslovak Socialist Republic still applies	10	10/ 0 if paid to public body or financial institution	5 / 0 on literary, artistic or scientific work including films
Slovenia	5	5/0	5
South Africa	5 if the beneficial owner is a company which holds at least 10% of the capital of the company paying the dividend / 10 in all other cases. A protocol to the treaty entered into force on 18 September 2015 but may apply retrospectively	0	0
Spain	0/5 if received by a company holding <10% of the capital of the paying company and in all cases if received by an individual or a company not limited at least partly by shares	0	0
Sweden	5/15 if <25% of votes	10/ 0 if paid to public body or financial institution	0
Switzerland (The treaty is effective from 01/01/2016)	0 (i) 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. (ii) a pension fund or other similar institution recognized as such for tax purposes, or (iii) the Government, a political subdivision, local authority or central bank of one of the two contracting states. 15% in all other cases.	0	0
Syria	0/15 if received by a company holding <25% of the capital of the paying company and in all cases if received by an individual or a company not limited at least partly by shares	10/ 0 if paid to public body or financial institution	15 / 10 on literary, dramatic, musical, artistic or scientific work, including films or tapes for TV or radio broadcasting
Thailand	10	15 / 10 on interest received from financial institutions, on interest paid in connection with industrial, commercial, scientific equipment or the sale or merchandise between two companies	5 for any copyright of literary, dramatic, musical, artistic, or scientific work / 10 on right to use industrial, commercial or scientific equipment / 15 on patents, trademarks, designs, models, plans, secret formulas or processes
Ukraine	15/5 is applicable if the dividend is received by a company owning at least 20% of the capital of the dividend paying company and has invested in the acquisition of shares or other rights of the dividend paying company of at least €100.000	2	5 for any copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience / 10 will be levied in all other cases
United Arab Emirates	0	0	0
United kingdom	15/0 applies to dividends paid to a company that controls, directly or indirectly, at least 10% of the voting power of the payer company, as well as in other situations where dividends are paid to a resident of Cyprus that is not entitled to the same tax credit to which a UK resident individual would be entitled in respect of the dividends / but local UK tax provides for 0 - so 0%	10	0/5 on films including films used for television programs
United States of America	15 / 5 if more than 10% of votes	10 / 0 if paid to the Government or a bank or a fin. Inst. Or in respect to debt obligations arising in connection with sale of property or the provision of services	0

2) Paid from Cyprus

*Important Notes:

*Low or no withholding taxes on outgoing dividends, interest and royalties (no withholding tax on dividends and interest – therefore there is no columns included below - no withholding tax on royalty payments for use of the rights outside Cyprus, 10% if the rights will be used in Cyprus (subject to DTT & EU Directives) and 5% on films (subject to DTT & EU Directives).

* If the rates of Cyprus tax are lower than those provided by the relevant treaty, then the lower rates are applicable in favor of the taxpayer.

*Possible use can be made of EU Directives to eliminate or reduce these rates - so rendering the treaty benefits is redundant. Treaties will be used where EU Directives are not applicable No tax is withheld when the royalty is paid for use outside Cyprus.

*The gross income derived from sources within the Republic, for technical assistance provided by any non-Cyprus resident person, is subject to 10% withholding tax. Such income is exempt from withholding tax if the services are provided by a permanent establishment in Cyprus.

*The gross income derived by an individual non-resident in Cyprus, from the exercise of any profession or vocation in Cyprus or of public entertainers not resident in the Republic, and the gross receipts of any theatrical or musical or other group of public entertainers, including football clubs and other athletic missions from abroad, derived from performances in the Republic is subject to 10% withholding tax.

*The gross income derived within the Republic by a non-resident person that has no permanent establishment in Cyprus in relation to services performed in the Republic with respect to the extraction, exploration or exploitation of the continental shelf, subsoil or natural resources, as well as the installation and exploitation of pipelines and other installations on the ground, the seabed or above the surface of the sea, is subject to 5% withholding tax.

Paid from Cyprus

Country	Royalties*Rights used within Cyprus(%)
Armenia	5
Austria	0
Bahrain (The treaty is effective from 01/01/2017)	0
Belarus	5
Belgium	0
Bosnia The treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia still applies	10 / 5 on cinematographic film royalties
Bulgaria	10 / 5 on cinematographic film royalties
Canada	10 / 5 on cinematographic film royalties / 0 on literary, dramatic musical or artistic work with the exception of films used for television programs
China	10 / 5 on cinematographic film royalties
Czech Republic	0 / 10 on patents, trademarks, designs, models, plans, secret formulas or processes, computer software or industrial, commercial, or scientific equipment, of for information concerning industrial, commercial or scientific experience.
Denmark	0
Egypt	10 / 5 on cinematographic film royalties
Estonia	0
Finland	0
France	0 /5 on films including films used for television programs
Germany	0
Greece	0 /5 on film royalties (except films shown on TV)
Guernsey The treaty is effective from 01/01/2016)	0
Hungary	0
Iceland	5
India	10 / 5 on cinematographic film royalties
Ireland	0 /5 on film royalties (except films shown on TV)
Italy	0
Kuwait	5
Latvia	0 if payer is a company that is resident in Cyprus and the beneficial owner of the income is a company (other than partnership) that is resident in Latvia / 5 for all other cases
Lebanon	0
Lithuania	5
Malta	10 / 5 on cinematographic film royalties
Mauritius	0
Moldova	5
Montenegro The treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia applies	10 / 5 on cinematographic film royalties
Norway	0
Poland	5
Portugal	10 / 5 on cinematographic film royalties
Qatar	5
Romania	5 / 0 if paid to the Government of the other State or to a financial institution
Russia	0
San Marino	0
Serbia The treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia still applies	10 / 5 on cinematographic film royalties
Seychelles	5
Singapore	10 / 5 on cinematographic film royalties
Slovakia The treaty between the Republic of Cyprus and the Czechoslovak Socialist Republic still applies	5 / 0 on literary, artistic or scientific work including films
Slovenia	5
South Africa	0
Spain	0
Sweden	0
Switzerland (The treaty is effective from 01/01/2016)	0
Syria	10 / 5 on cinematographic film royalties
Thailand	5 for any copyright of literary, dramatic, musical, artistic, or scientific work / 10 on right to use industrial, commercial or scientific equipment
Ukraine	5 for any copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience / 10 will be levied in all other cases.
United Arab Emirates	0
United Kingdom	0/5 on films including films used for television programs
United Sates of America	0

* No tax is withheld when the royalty is paid for use outside Cyprus

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