Received in Cyprus
Dividends % Interest % Royalties %
Armenia 0(1) 5(2) 5
Austria(34) 10 0 0
Belarus 5(3) 5 5
Belgium 10(4) 10(5) 0
Bulgaria 5(6) 7(7) 10(8)
Canada 15 15(9) 10(10)
China 10 10 10
Czech Republic 0(11) 0 10
Denmark 0(12) 0 0
Egypt 15 15 10
Estonia 0 0 0
Finland 5(13) 0 0
France 10(14) 10(15) 0(16)
Germany 5(14) 0 0
Greece 25 10 0(17)
Hungary 5(4) 10(18) 0
India 10(14) 10(18) 5(19)
Ireland 0 0 0(17)
Italy 15 10 0
Kuwait 10 10(18) 5(20)
Kyrgyzstan(35) 0 0 0
Lebanon 5 5(5) 0
Malta 0(22) 10(18) 10
Mauritius 0 0 0
Moldova 5(6) 5 5
Montenegro(36) 10 10 10
Norway 5(21) 0 0
Poland 0(23) 5(18) 5
Portugal 10 10 10
Qatar 0 0 5
Romania 10 10(18) 5(20)
Russia 5(24) 0 0
San Marino 0 0 0
Serbia(36) 10 10 10
Seychelles 0 0 5
Singapore 0 10(25) 10
Slovakia(37) 10 10(18) 5(20)
Slovenia 5 5(2) 5
South Africa 0 0 0
Spain(34) 0(27) 0 0
Sweden 5(4) 10(18) 0
Syria 0(4) 10(18) 15(26)
Tajikistan(35) 0 0 0
Thailand 10 15(29) 5(30)
Ukraine 5(28) 2 5
United Arab Emirates(27) 0 0 0
United Kingdom 0(31) 10 0(16)
USA 5(32) 10(33) 0
Uzbekistan(35) 0 0 0


Paid from Cyprus(a)
Dividends % Interest % Royalties %
Non-treaty countries 0 0 0(b)
Armenia 0(1) 5(2) 5
Austria(34) 10 0 0
Belarus 5(3) 5 5
Belgium 10(4) 10 0
Bulgaria 5(6) 7(7) 10
Canada 15 15(9) 10(10)
China 10 10 10
Czech Republic 0(11) 0 10
Denmark 0(12) 0 0
Egypt 15 15 10
Estonia 0 0 0
Finland 5(13) 0 0
France 10(14) 10(15) 0(16)
Germany 5(14) 0 0
Greece 25 10 0(17)
Hungary 0 10(18) 0
India 10(14) 10(18) 15(19)
Ireland 0 0 0(17)
Italy 0 10 0
Kuwait 10 10(18) 5(20)
Kyrgyzstan(35) 0 0 0
Lebanon 5 5(5) 0
Malta 15 10(18) 10
Mauritius 0 0 0
Moldova 5(6) 5 5
Montenegro(36) 10 10 10
Norway 0 0 0
Poland 0(23) 5(18) 5
Portugal 10 10 10
Qatar 0 0 5
Romania 10 10(18) 5(20)
Russia 5(24) 0 0
San Marino 0 0 0
Serbia(36) 10 10 10
Seychelles 0 0 5
Singapore 0 10(25) 10
Slovakia(37) 10 10(18) 5(20)
Slovenia 5 5(2) 5
South Africa 0 0 0
Spain(34) 0(27) 0 0
Sweden 5(4) 10(18) 0
Syria 0(4) 10(18) 15(26)
Tajikistan(35) 0 0 0
Thailand 10 15(29) 5(30)
Ukraine 5(28) 2 5
United Arab Emirates(27) 0 0 0
United Kingdom 0 10 0(16)
USA 0 10(33) 0
Uzbekistan(35) 0 0 0


Notes:

(a) Under the Cyprus tax legislation, payments of dividends, interest and royalties to non-residents of Cyprus are exempt from withholding tax in Cyprus.

(b) Royalties earned for the use within Cyprus are subject to 10% withholding tax. Also, film and TV rights are subject to 5% withholding tax.

(1) A withholding tax of 5% applies if the beneficial owner has invested in the issued share capital of the paying company less than €150.000.

(2) No subject to withholding tax if paid to the Government, or to the Central Bank or to a local authority.

(3) This withholding tax rate applies if the amount invested by the beneficial owner is above €200.000 irrespective of the percentage of voting shares acquired. A withholding tax of 10% applies if received by a holder of at least 25% of the issued share capital of the paying company. Otherwise the 15% withholding tax rate will apply.

(4) A withholding tax rate of 15% applies if received by a company controlling less than 10% of the voting shares.

(5) No withholding tax applies if paid to the Government of the other State, a political subdivision or a local authority, the National Bank or any institution the capital of which is wholly owned by the State or a political subdivision or a local authority or in the form of interest income from bank deposits.

(6) A withholding tax of 5% applies if the dividend is received by a company owning directly at least 25% of the issued share capital, otherwise a 10% withholding tax will apply.

(7) There is no withholding tax if paid to or is guaranteed by the Government or statutory body or the Central Bank.

(8) The withholding tax rate will not apply, if 25% or more of the issued share capital of the Cypriot resident is held directly or indirectly by the Bulgarian resident paying the royalties and the Cyprus tax resident company pays less than the normal tax rate.

(9) There is no withholding tax if paid to the Government or for export guarantee.

(10) There is no withholding tax on artistic work, on dramatic, musical and on literary, except on films used for television programs.

(11) There is no withholding tax if the beneficial owner is a company (not a partnership) which owns directly at least 10% of the issued share capital of the company paying the dividends where such holding is being possessed for an uninterrupted period of not less than 12 months. In all other cases a 5% withholding tax will apply.

(12) There is no withholding tax if paid to the government or Central Bank of the other state or pension fund or other similar institution providing pension schemes or if the beneficial owner is a company (not a partnership) which owns directly at least 10% of the issued share capital of the company paying the dividends, where such holding is being possessed for an uninterrupted period of no less than 12 months. In all other cases a withholding tax of 15% will apply.

(13) A withholding tax of 5% will apply if the dividend is received by a company (not a partnership) which holds directly at least 10% of the voting power in the company paying the dividends. In all other cases a withholding tax of 15% will apply.

(14) The withholding tax rate will apply if received by a company controlling more than or equal to 10% of the issued share capital. In all other cases a withholding tax of 15% will apply.

(15) There is no withholding tax if paid to the Government of the other State or bank or financial institution.

(16) A withholding tax of 5% will apply on film royalties including films shown on TV.

(17) A withholding tax of 5% will apply on film royalties with the exception for films shown on TV.

(18) There is no withholding tax if paid to the Government of the other State or to a financial institution.

(19) The withholding tax rate is 15% as per the treaty, hence restricted to Cyprus legislation rate. The withholding tax rate of 10% applies for payments of a technical, managerial, or consulting nature.

(20) There is no withholding tax on literary, artistic or scientific work including films.

(21) There is no withholding tax if paid to a company controlling at least 50% of the voting issued share capital.

(22) As per the treaty the tax on the gross amount of the dividends shall not exceed the chargeable on the profits out of which the dividends are paid.

(23) There is no withholding tax if the beneficial owner is a company (not a partnership) which owns directly at least 10% of the issued share capital of the company paying the dividends, where such holding is being possessed for an uninterrupted period of no less than 24 months. In all other cases a withholding tax of 5% will apply.

(24) There is 10% withholding tax if received by company, which the parent has invested less than €100,000.

(25) There is no withholding tax if paid to the government; however there is 7% withholding tax if paid to a bank or similar financial institution.

(26) There is 10% withholding tax on literary, musical, artistic work, films and TV royalties.

(27) There is no withholding tax if the dividend is received by a company (not a partnership) owns at least 10% of the issued share capital of the dividend paying company. In all other cases a withholding tax of 5% will apply.

(28) There is 5% withholding tax if the dividend is received by a company owns at least 20% of the issued share capital of the dividend paying company or has invested in the acquisition of shares (and/or other similar rights) of the dividend paying company of at least €100.000. In all other cases a withholding tax of 15% will apply.

(29) There is 10% withholding tax on interest received by financial institutions, on interest paid in connection with industrial, commercial, scientific equipment or the sale or merchandise between two companies.

(30) There is 10% withholding tax on right to use industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience and 15% withholding tax for patents, trademarks, designs, models, plans, secret formulas or processes.

(31) As per the treaty, there is 15% withholding tax, however the local taxation provides for 0% withholding tax.

(32) There is 5% withholding tax if received by a company owns at least 10% of the voting issued share capital. In all other cases a withholding tax of 15% will apply.

(33) There is no withholding tax 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.

(34) The treaty will enter into force in 2014.

(35) The treaty between the Republic of Cyprus and the United Soviet Socialist Republic still applies for these countries.

(36) The treaty between the Republic of Cyprus and the Socialist Federal Republic of Yugoslavia still applies.

(37) The treaty between the Republic of Cyprus and the Czechoslovak Socialist Republic still applies.