Table of Conventions of Double Taxation

Reference to the notes is in brackets next to the percentages and they apply for payments in both directions, unless otherwise provided. All rates are in percentages.

All the factors are in percentages:

 

 

 Country

Dividents

Rights

Interests

Income in Cyprus 

Payments from Cyprus

Income in Cyprus 

Payments from Cyprus

Income in Cyprus 

Payments from Cyprus

Austria

10

10

0

0

0

0

Belgium

10

10

10

10

0

0

Bulgaria

 0

0

0

0

0

0

Canada

5

15

10

10 (8)

15

15(11)

China

10

10

10

10

10

10

CIS

0

0

0

0

0

0

Czech Republic

10

10

5

5 (9)

10

10 (12)

Denmark

10

10 (1)

0

0

10

10(13)

Egypt

15

15

10

10

15

15

France

10

10 (2)

0

0 (10)

10

10 (13)

Germany

15

15 (3)

0

0 (10)

10

10 (12)

Greece

25

25

0

0

10

10

Hungary

5 (1)

nil

0

0

10

10 (12)

India

15

15 (2)

15

15

10

10 (12)

Ireland

0

0

0

0 (10)

0

0

Italy

15

0

0

0

10

10

Kuwait

10

10

5

5 (9)

10

10 (12)

Malta

(4)

15

10

10

10

10

Mauritius

0

0

0

0

0

0

Norway

0

0 (5)

0

0

0

0

Poland

10

10

5

5 (9)

10

10 (12)

Romania

10

10

5

5

10

10

Russia

5/10

5/10

0

0

0

0

Slovakia

10

10

5

5 (9)

10

10 (12)

Sweden

15

10 (1)

0

0

10

10 (12)

Syria

0

0 (1)

15

15 (16)

10

10

Thailand

10

10

10

10

5/10/15

5/10/15

United Kingdom

15

0 (6)

0

0 (10)

10

10

U.S.A

0 (7)

0

0

10 

10 (14)

Yugoslavia

10

10

10

10

10

10

 

   1. 15% if paid to a company holding a percentage of 25% or less of the share capital.
   2. 15% if paid to a company holding a percentage of 10% or less of the share capital.
   3. 10% if paid to a company holding less than 25% of the share capital of the company paying it. However, in the case when the German Corporate Tax provides for the taxation for distributed profits is lower than that in the non-distributed profits and the difference between the rates is 15% or more, the tax withheld increases from 10% to 27%. In all other cases the rate is 15%.
   4. Withholding of tax shall not exceed the tax imposed on profits on which dividends were paid.
   5. 5% if paid to a company controlling under 50% of the voting rights.
   6. If paid to company controlling under 10% of the voting rights, is entitled to the return of the additional deducted ACT in the UK (if it controls more than 10% of the voting rights then it is not entitled to any return).
   7. 15% if paid to a company controlling under 10% of the voting rights.
   8. Zero for the production of literary, theatrical, musical or artistic work.
   9. Zero for the production of literary, theatrical or scientific work the film and the television rights.
  10. 5% for films and television rights.
  11. Zero if paid to the government or for export guaranty.
  12. Zero if paid to the government of another country.
  13. Zero if paid to the government of another country in respect to bank loans related to the sale on credit of any industrial, commercial or scientific equipment or any goods.
  14. Zero if paid to a government, bank or financial institution.
  15. Zero if the rights are related to literary, artistic or scientific work, including films, television or radio productions.
  16. 10% for rights on the use of literary, artistic or scientific work including film productions for the cinema or for television or a radio station.