Cyprus: Cyprus and Latvia sign DTA

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

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


Cyprus: Cyprus and Latvia sign DTA

intl-updates-small.jpg

The details of the first agreement for the avoidance of double taxation (DTA) between Cyprus and Latvia became available in August 2016, providing information on the various applicable tax rates.

christodoulou.jpg

Andri Christodoulou

The DTA, which is based on the 2010 OECD Model Convention, was signed on May 24 2016 and ratified by both parties on June 3 2016. The agreement is expected to contribute to the further development of the economic relations between Cyprus and Latvia, as well as with other countries.

The main withholding tax rates with respect to dividends, interest and royalties are as follows:

  • 0% withholding tax on dividends if the beneficial owner is a company (other than a partnership), and 10% in all other cases;

  • 0% withholding tax on interest payments made to a company resident in the other contracting state that is the beneficial owner thereof. If the beneficial owner is not the recipient company of the interest then the withholding tax rate will be 10%; and

  • 0% withholding tax on royalty payments made to a company resident in the other contracting state that is the beneficial owner thereof. If the recipient company is not the beneficial owner of the royalty, then the withholding tax rate will be 5%.

Separately, Article 4 of the DTA does not provide for the standard tie-breaker rule for determining the residence of a taxpayer, other than an individual, that is a resident of both states. In this situation, dual residence is resolved by the competent authorities of the two states by mutual agreement.

Article 5 of the agreement on permanent establishments (PEs) provides a nine-month duration criteria that a building site, construction or assembly or installation project, or a connected supervisory or consultancy activity must fulfil in order to constitute a PE.

Although the double tax treaty is based on the OECD 2010 Model Convention, Article 7 of the Cyprus-Latvia DTA is based on the 2008 OECD Model Convention.

Meanwhile, Article 8 on shipping and air transport provides that profits of an enterprise of a state from the operation of ships or aircraft in international traffic are taxable only in that state.

The treaty also includes articles relating to offshore activities and on independent personal services (Article 14) in line with the UN Model (2001). Article 26 (exchange of information) is based on the OECD Model.

The treaty will take effect from January 1 in the year after all legal formalities and ratifications are completed to bring the treaty into force.

Andri Christodoulou (andri.christodoulou@eurofast.eu)

Eurofast Taxand Cyprus

Tel: +357 22 699 224

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

As joint audits, data sharing and pillar two reshape tax controversy, multinational groups can no longer afford to manage disputes one jurisdiction at a time
Brazil's tax system is being reshaped by VAT , pillar two and TP reform. Fallet explains why those changes convinced him to lead a new practice
The agreement with Daribatech, alongside recent high-profile investment in talent, suggests the firm is gearing up for a significant push in the region
Several factors have led to a steady transition of TP work away from traditional advisers and towards full-service law firms, DLA Piper’s new TP leader says
Julian Balson's departure from EY's Tier 1 tax controversy practice for lower-ranked Fieldfisher represents one of the more eye-catching UK hires of the year
Former IRS commissioner Danny Werfel argues that the biggest obstacle to AI adoption in tax is not technology, but trust, and introduces a practical AI risk framework to help
Howell takes a deep dive into how he led the landmark PepsiCo dispute, discusses the ATO's enforcement priorities, and emphasises KordaMentha's market ambitions
Global tax leader David Linke said that the TaxSim gaming programme could replace aspects of traditional face-to-face learning
Former ATO economist Craig Silverwood is joining from Australian firm MinterEllison
The rebranding, which will see changes to signage, visual identity and digital properties, is scheduled to be completed by the end of this year
Gift this article