Double tax treaties 2013

Notes

1. Under Cyprus legislation there is never any WHT on dividends and interest paid to non-residents of Cyprus

2. Royalties earned on rights used within Cyprus are subject to WHT of 10%

3. A rate of 5% on film and TV royalties

4. Nil if paid to a government/Central Bank/ Public Authority or for export guarantee

5. Nil on literary, dramatic, musical, or artistic work

6. Nil if paid to the government/Central Bank/ Public Authority of the other state

7. This rate applies for patents, trademarks, designs or models, plans, secret formulas,
   or processes,or any industrial, commercial, or scientific equipment, or for information
   concerning industrial,commercial, or scientific experience

8. A rate of 15% if received by a company controlling less than 25% of the voting power.

9. A rate of 15% if received by a person controlling less than 10% of the voting power

10. Nil if paid to a government, bank, or financial institution

11. A rate of 5% on film royalties

12. A rate of 5% if received by a person controlling less than 50% of the voting power

13. This rate applies to individual shareholders regardless of their percentage of shareholding.
    Companies controlling less than 10% of the voting shares are also entitled to this rate

14. A rate of 10% for payments of a technical, managerial, or consulting nature

15. Treaty rate is 15%, therefore restricted to Cyprus legislation rate

16. A rate of 10% if a dividend is paid by a company in which the beneficial

17. If investment is less than EUR 200,000, dividends are subject to 15% WHT
    which is reduced to 10% if the recipient company controls 25% or more of the paying company

18. No WHT for interest on deposits with banking institutions

19. Kyrgyzstan, Tajikistan, and Ukraine apply the USSR/Cyprus treaty

20. A rate of 10% on interest received by a financial institution or when it relates
    to sale on credit of any industrial, commercial, or scientific equipment or of merchandise

21. This rate applies for any copyright of literary, dramatic, musical, artistic, or scientific work.
    A 10% rate applies for industrial, commercial, or scientific equipment.
    A 15% rate applies for patents, trade marks, designs or models, plans, secret formulas, or processes

22. This rate applies to companies holding directly at least 25% of the share capital
    of the company paying the dividend. In all other cases the WHT is 10%

23. This rate does not apply if the payment is made to a Cyprus international business entity
    by a resident of Bulgaria owning directly or indirectly at least 25% of the share capital of the Cyprus entity

24. A rate of 7% if paid to a bank or financial institution

25. Serbia, and Montenegro apply the Yugoslavia/Cyprus treaty

26. This rate applies if received by a company (excluding partnerships) that holds directly 25% of the shares.
    A rate of 10% applies in all other cases

27. Applies to any consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work
    (including cinematograph films and films, tapes or discs for radio or television broadcasting), computer software,
    any patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial,
    commercial, or scientific experience

28. This rate applies if received by a company (excluding partnership) which holds directly at least 10% of the shares
    for an uninterrupted period of no less than one year. 5% applies in all other cases

29. 10% for patent, trademark, design or model, plan, secret formula or process, computer software or industrial, commercial,
    or scientific equipment, or for information concerning industrial, commercial, or scientific experience

30. A rate of 5% if a dividend is paid by a company in which the beneficial owner has invested less than EUR 150.000

31. The provisions of the Parent-Subsidiary EU directive are applicable

32. A rate of 15% if received by a company controlling less than 10% of the share capital of the paying company or the duration
    of any holding is less than one uninterrupted year

33. A new treaty has been signed and it will apply as from 1st January of the year following the year of ratification.
    This rate applies if the recipient company (partnership is excluded) holds directly 10% of the shares for an uninter­rupted period
    of at least 2 years. 5% in all other cases.