Cyprus: Cyprus updates DTAs and protocols and signs new ones

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cyprus: Cyprus updates DTAs and protocols and signs new ones

intl-updates

During 2017 and the first quarter of 2018, various developments have taken place in Cyprus as regards double tax agreements (DTAs), with a number of new DTAs, protocols and amending protocols being signed and coming into force.

The list of countries with which Cyprus maintains DTAs stands at 63, which is a substantial number for an island as small as Cyprus.

Specifically and most recently, new DTAs have been signed with Saudi Arabia (on January 3 2018) and the UK (on March 22 2018). Both treaties are expected to enter into force in 2019. The beginning of 2018 marked the entry into force of DTAs signed earlier with Barbados, Iran and Jersey.

New double tax treaty with the UK

The new DTA which was signed between the UK and Cyprus, replaces the existing DTA between the two countries that had been in effect since 1975 (as amended in 1980). The new DTA provides for the following:

  • No withholding tax on dividends, with the exception of dividends that are paid out of profits resulting from investment vehicles which distribute most of their income annually and whose income arises from immovable property exempt from tax;

  • No withholding tax on interest and royalties, provided that such payments are considered to be arm's-length transactions;

  • Capital gains tax arising on the sale of immovable property (directly or indirectly) is paid in the country where the property is situated; and

  • Tax on pensions is paid in the country where an individual is considered to be a tax resident (certain exemptions apply).

The new DTA also includes a limitation of benefits provision/principle purpose test in accordance with the minimum standards of the BEPS project.

DTA with Saudi Arabia

The DTA signed between Cyprus and Saudi Arabia entails the following important provisions:

  • No withholding tax on dividends, provided that a minimum 25% participation exists. In all other cases, a 5% withholding tax will be applied;

  • No withholding tax on interest;

  • Withholding tax ranging between 5% and 8% on royalties; and

  • Capital gains tax arising on the alienation of shares is paid in the state where the seller is resident, provided that the minimum 25% participation test is met at any time within the 12-month period leading up to the disposal of the shares.

Barbados DTA

The DTA between Cyprus and Barbados came into effect on January 1 2018 and provides for no withholding tax on dividends, interest, and royalties.

San Marino new protocol

The main changes introduced by the signing of the new protocol between Cyprus and San Marino relate to exchange of information procedures between the two countries.

The new and revised DTAs concluded by Cyprus enhance the pathway for investment into the countries concerned. New DTAs and changes to existing DTAs can have a substantial impact on existing structures in such countries.

Nicolaou

Christodoulou

Maria

Nicolaou

Andri

Christodoulou

Maria Nicolaou (maria.nicolaou@eurofast.eu) and Andri Christodoulou (andri.christodoulou@eurofast.eu)

Eurofast

Tel: +357 22 699 224

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

Brazil appears to be adopting protocols to align national taxation with international standards, but recent changes are not immune from criticism, experts tell ITR
The US president did not have the authority to impose the tariffs, a court ruled; in other news, Fried Frank and Crowe Ireland made key tax hires
Pillar two considerations have become a fact of life for taxpayers everywhere, not least in Switzerland, where companies nonetheless continue to be active with investment
The Dutch TP software company’s co-founder tells ITR about speeding up documentation processes, following in Steve Jobs’s footsteps, and what makes tax cool
The ruling underscores the need for companies to provide robust and defensible valuations of intangible assets, one partner tells ITR
Pillar two is certain to be a game-changer for tax advisers and their clients. Russell Gammon of Tax Systems outlines 10 reasons why
Despite a general decline in corporate tax rates around the world, jurisdictions are now more reliant on it than in 1990, a Tax Foundation economist found
Australian law firm Webb Henderson’s report said PwC had met 46 of 47 targets; in other news, the OECD has issued new transfer pricing country profiles
The arrival of a seven-strong team from Baker McKenzie will boost WTS Germany’s transfer pricing capabilities and help it become ‘a European champion’, the firm’s CEO said
Germany has forgotten to think about digital reporting requirements, a WTS partner claimed at ITR’s Indirect Tax Forum 2025
Gift this article