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

Sara Morgan is due to join Joseph Hage Aaronson & Bremen as a partner in London, ITR understands
The newly combined tax team has already worked on thousands of joint client matters, leaders from McDermott Will & Schulte tell ITR
As AI becomes increasingly intuitive and idiot-proof, its tax applicability is becoming impossible to overstate
New data on public CbCR showed uneven adoption, as Singapore advanced pillar two compliance and firms expanded their tax capabilities
Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention
With a stark divergence between MNEs that prepared early and those rushing to catch up, advisers must remain agile with all manner of compliance risks
The EU agreed new cooperative and investigative measures to tackle VAT fraud, while Hungary faced legal action and Lavez Coutinho expanded its indirect tax team
The arrival of a team from Brazilian rival Costa Tavares Paes Advogados brings SiqueiraCastro’s tax headcount to seven partners and 30 associates
CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour
Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes
Gift this article