Cyprus: Cyprus expands its treaty network with Lithuania and Guernsey

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 expands its treaty network with Lithuania and Guernsey

kokoni.jpg

Zoe Kokoni

Cyprus, which has been long-established as a solid economic and business centre worldwide, seeks to reinforce its title as a beneficial investment hub by expanding its double tax treaty network and creating stronger economic and trade relations with other contracting states.

Cyprus and Lithuania DTT

On June 21 2013, Cyprus and Lithuania signed their first double tax treaty (DTT). Since then, the countries have ratified the agreement, which will enter into force on January 1 2015.

In summary, the new provisions of the ratified agreement cover:

  • Dividends: No withholding tax (0%) where the recipient is a company and

    • is the beneficial owner of the dividends; and

    • owns at least (minimum) 10 % capital of the company.

    • In all other cases a 5% withholding tax shall be applicable.

    • Interest: No withholding tax (0%).

  • Royalties: 5% withholding tax provided that the recipient is the beneficial owner.

  • Capital gains: gains, resulting from the disposal of shares, are taxable in the country in which the alienator of the shares is tax resident.

Cyprus and Guernsey DTT

On July 15 2014 Cyprus and Guernsey signed a double taxation avoidance agreement, which will enter into force upon the ratification of the agreement by the two contracting states. The agreement is based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital.

Briefly, the main provisions of the agreement between the two contracting states provide a 0% withholding tax rate for dividends, interest and royalty payments. For capital gains, gains for a resident of one of the two countries (ex. A), resulting from the disposal of immovable property in the other country (ex. B), will be taxed in the country where the immovable property is situated (ex. B). Gains resulting from the disposal of shares are taxable in the country in which the alienator of the shares is tax resident.

Zoe Kokoni (zoe.kokoni@eurofast.eu)
Eurofast, Cyprus office

Tel: +357 22 699 222

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

The arrival of Alex Anderson swiftly follows that of funds tax specialist Stuart Alter and suggests the Tier 3-ranked firm has higher ambitions
One of the two appointments is EY’s Gordon McIntosh, who becomes the big four firm’s second senior tax departure in September
Balson's move from a Tier 1 practice to a Tier 3 competitor looks counterintuitive. The market data suggests it is anything but
Awards
It was another banner year for Deloitte, which picked up more awards than any other firm at a gala ceremony held at The Londoner in Leicester Square
The big four firm has been embroiled in a scandal over partners’ misuse of confidential board papers to pitch for and win corporate audits for Westpac and Dexus
Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector
As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands
World Tax data shows Matt Donnelly is moving from a Tier 3 transactional tax practice to a Tier 1 market leader, underlining Kirkland & Ellis’s pull at the top end of the market
Nexdigm's Maulik Doshi and infer360 co-founder Sunil Agarwal dig deeper into their partnership and discuss why the tax technology industry is consolidating
Advisers won’t be short of work in a world of increased valuation disputes, documentation requirements and behavioural responses from clients seeking to protect their wealth
Gift this article