Cyprus: Cyprus expands its double tax treaty network with Spain and Portugal

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

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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

Cyprus: Cyprus expands its double tax treaty network with Spain and Portugal

philippou.jpg

Eylem Philippou

To enhance its position as a financial business centre and to attract more international business, Cyprus has recently signed two double tax treaties with Spain and Portugal. These tax treaties also serve to maintain and strengthen its economic and commercial ties with other countries. The double tax treaty signed with Portugal on November 19 2012 is a step further in bilateral relations between the two countries, especially following Cyprus's removal from Portugal's blacklist of jurisdictions back in 2011.

The new treaty is based on OECD Model Convention, with the withholding tax rate set for dividends, interest and royalties at 10%. Gains arising from the alienation of shares held in property rich companies may be taxed in the state in which the property is located.

The signing of the treaty, as well as the removal of Cyprus from Portugal's blacklist, is expected to increase investments between the two countries. Now Portugal can leverage Cyprus as a gateway to Russia and ex-Soviet Union countries where Cyprus already has favourable treaties in place. Cyprus can also leverage Portugal as a gateway to enter into South American countries.

Cyprus also recently signed a treaty with Spain on February 14 2013. Again the treaty is based on the OECD Model Convention, including the latest provisions on exchange of information (art. 26). The main provisions of the treaty are as follows:

    The withholding tax on dividends is 5%; No withholding tax on interest; No withholding tax on royalties; and Gains arising from the alienation of shares held in property rich companies may be taxed in the state in which the property is located.

With the signing of this treaty, Cyprus is also expected to be removed from the Spanish blacklist in the near feature.

Both treaties are expected to enter into force once the latter ratification is completed and will be applicable from January 1 of the calendar year following the year in which it entered into force.

It is important to mention that, irrespective of the treaty provisions, Cyprus does not impose withholding taxes on payments made to non-residents on dividends, interest and royalties (for royalties if the rights exercised outside of Cyprus). Gains from securities are exempt from taxation, as well as the gains from immovable property situated outside of Cyprus. In addition, tax sparing credit provisions are included in Cyprus's domestic legislation, which allows relief from double taxation. Multinationals with operations in Cyprus and Portugal or Spain stand to benefit.

Eylem Philippou (eylem.philippou@eurofast.eu)

Eurofast Taxand

Tel: +357 22 699 222

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

Over two-thirds of survey respondents back the continuation of the UK’s digital services tax, research commissioned by the Fair Tax Foundation also found
Given the US/G7 pillar two deal, the OECD is in danger of being replaced by the UN as the leading global tax reform forum
Cinven’s latest investment follows its acquisition of a stake in Grant Thornton UK in December; in other news, a barrister listed by HMRC as a tax avoidance promoter has alleged harassment
CIT base narrowing measures remain more prevalent than increased CIT rates, the report also highlighted
ITR's parent company, LBG, will acquire The Lawyer, a leading news, intelligence and data-driven insight provider for the legal industry, from Centaur Media
KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter
Rishi Joshi, of the Institute of Chartered Accountants of India, warns of potential judicial overreach as assets are recharacterised to bypass a legislative exclusion
Only 2% of in-house survey respondents said they were ‘heavy’ users of AI for TP, Aibidia’s report also found
There was a ‘deeply embedded culture within PwC that routinely disregarded formal confidentiality obligations,’ the chairman of Australia’s Tax Practitioners Board said
Jennifer Best was most recently the acting commissioner of the IRS’s large business and international division
Gift this article