All material subject to strictly enforced copyright laws. © 2022 ITR is part of the Euromoney Institutional Investor PLC group.

Cyprus: Cyprus and Georgia sign tax treaty protocol


Myranda Chatzimatthaiou

On May 13 2015, during the 24th annual meeting of the European Bank for Reconstruction and Development (EBRD) in Tbilisi, Georgia and Cyprus signed an agreement for the avoidance of double tax payment (double tax treaty).

The agreement signed by Cyprus and Georgia is harmonised with the OECD Model Tax Convention with some modifications. In particular, any building site or construction or installation project, or any supervisory activities in connection with such site or project will now only constitute a permanent establishment if it lasts more than nine months.

Moreover, the withholding tax rate for dividends is set at 0% of the gross amount and withholding tax on interest is also zero-rated, as is withholding tax on royalties.

Capital gains derived by a resident of a contracting state from the disposal of immovable property situated in the other contracting state may be taxed in that other state.

Capital gains that arise by a resident of a contracting state from the disposal of shares in a company are to be taxed only in the contracting state where the alienator is resident.

The agreement has been signed in order to strengthen the economic relations between the two countries, to eliminate the fiscal evasion with respect to taxes on income and on capital and in order to attract investments in both countries.

The treaty was published in the Official Gazette of the Republic of Cyprus on May 29 2015 and will enter into force on January 1 2016, provided that Cyprus and Georgia confirm that their formal ratification procedures have been completed.

Myranda Chatzimatthaiou (

Eurofast Cyprus Office

Tel : +357 22 699 222


More from across our site

This week European Commission officials consider legal loopholes to secure minimum corporate taxation, while Cisco and Microsoft shareholders call for tax transparency.
The fast-food company’s tax settlement with French authorities strengthens the need for businesses to review their TP arrangements and documentation.
The full ALP model will be adopted through a new TP regime, which is set to boost the country’s investments and tax certainty.
Tax professionals have called on the UK government to reconsider its online sales tax as it would affect the economy at the worst time.
Tax professionals have called on companies to act urgently to meet e-invoicing compliance targets as the EU plans to ramp up digitisation.
In the wake of India’s ambitious 25-year plan for economic growth, ITR has partnered with leading tax commentators to discuss what the future will look like for India and for the rest of the world.
But experts cast doubt on HMRC's data and believe COVID-19 would have increased the revenue shortfall.
EY’s plan to separate its auditing and consulting businesses might lessen scrutiny from global regulators, but the brand identity could suffer, say sources.
Multinationals are asking world leaders to put a scale on carbon pricing to tackle climate change at the 48th G7 summit in Germany, from June 26 to 28.
The state secretary told the French press that the country continues to oppose pillar two’s global minimum tax rate following an Ecofin meeting last week.
We use cookies to provide a personalized site experience.
By continuing to use & browse the site you agree to our Privacy Policy.
I agree