Cyprus tax treaties
Double taxation treaties, also known as double taxation agreements, are designed to protect against the risk of an individual or a corporate entity being taxed twice where the same income is taxable in two states. Double taxation treaties are agreements between two states which are designed to:
- protect against the risk of double taxation where the same income is taxable in two states
- provide certainty of treatment for cross-border trade
- prevent tax discrimination against Cyprus-based-registered business interests abroad
Many well-known investment tax-haven jurisdictions might have a low or nil corporate tax. However, these jurisdictions do not have an extensive network of double tax treaties such as Cyprus – they are more 'shady' tax solutions. Cyprus can offer extensive double taxation agreements because it is a credible jurisdiction, meeting European Union directives and listed on the OECD white list of credible locations. Indeed, this is what truly makes Cyprus an ideal location for registering a company and benefiting from tax efficiency.
Cyprus has concluded double tax treaties with over 50 countries, whilst a further 40 are currently being negotiated. Most of these tax treaties with Cyprus follow the OECD Model Convention, although the US-Cyprus tax treaty follows the most recent model of United States Agreements. The following countries have double-tax treaties with Cyprus:
- Azerbaijan
- Armenia
- Austria
- Belarus
- Belgium
- Bulgaria
- Canada
- China
- CIS (ex-USSR)
- Czech Republic
- Denmark
- Egypt
- Estonia
- Finland
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- France
- Germany
- Greece
- Hungary
- Iceland
- India
- Iran
- Ireland
- Italy
- Jersey
- Kuwait
- Kyrgyzstan
- Lebanon
- Lithuania
|
- Luxembourg
- Malta
- Mauritius
- Moldova
- Norway
- Poland
- Portugal
- Qatar
- Romania
- Russia
- San Marino
- Serbia and Montenegro
- Seychelles
- Singapore
|
- Slovakia
- Slovenia
- South Africa
- Spain
- Sweden
- Syria
- Tajikistan
- Thailand
- Ukraine
- United Kingdom
- United States of America
- Yugoslavia
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Cyprus also has tax-sparing provision with 15 countries, including Canada; the Czech Republic; Denmark; Germany; Greece; India; Ireland, Italy; Malta; Romania; Slovakia; Sweden; Syria; the United Kingdom; and Yugoslavia. In addition, Cyprus has signed agreements on the promotion and protection of investments with over 20 other countries. These bilateral agreements contain guarantees against discriminatory treatment, safeguards for the repatriation of capital and profits in a freely convertible currency and compensation provisions in the event that property is expropriated, among other clauses. Countries with which Cyprus has such agreements include: Armenia, Belgium/Luxembourg, Bulgaria, Czech Republic, China, Egypt, Greece, Hungary, India, Israel, Lebanon, Libya, Malta, Moldova, Poland, Romania, San Marino, Seychelles, Serbia and Montenegro, and Syria.
For more detail about double taxation treaties with Cyprus, visit the tax departments Double Tax Agreements
Cyprus has concluded double taxation treaties with over 50 countries, including the China, Canada, India, Ireland, EU countries, Japan, Russia and CIS, Singapore, South Africa, the UAE, USA, and the UK, among others, whilst negotiations are underway with a further 40 countries. Indeed, this extensive list of double tax treaties (and still more to come) is the one of the key tax advantages to registering a company in Cyprus.
Below is a list of Cyprus Double Taxation Treaties and each treaties date of application:
Country |
Date of signature tax treaty/protocol |
Date of when tax treaty came into force |
Date of when the tax treaty was published in the official Republic of Cyprus Gazette (Number and date) |
Austria |
20 Mar 1990 |
10 Nov 1990 |
2500 27 Apr 1990 |
Bulgaria |
30 Oct 2000 |
3 Jan 2001 |
3461 30 Dec 2000 |
Belarus |
29 May 1998 |
12 Feb 1999 |
3273 9 Oct 1998 |
Belgium |
14 May 1996 |
8 Dec1999 |
3365 19 Nov 1999 |
Canada |
2 May 1984 |
3 Sep1985 |
2053 31 May 1985 |
China |
25 Oct1990 |
5 Oct 1991 |
2578 22 Feb 1991 |
Denmark Treaty Notes New Agreement |
26 May 1981 11 Oct 2010 |
10 Aug 1981 10 Apr 1982 |
1704 17 Jul 1981 2034 24 Sep 1982 |
Egypt |
18 Dec1993 |
14 Mar1995 |
2865 11 Mar 1994 |
France |
18 Dec1981 |
1 April 1983 |
1468 9 Jul 1982 |
Germany (new Agreement) |
9 May 1974 18 Feb 2011 |
11 Oct 1977 2011 |
1199 27 Jun 19752011 |
Greece |
30 Mar1968 |
16 Jan 1969 |
651 10 May 1968 |
Hungary |
30 Nov1981 |
24 Nov 1982 |
862 7 May 1982 |
India |
13 Jun 1994 |
21 Dec 1994 |
2921 4 Nov 1994 |
Ireland |
24 Sep1968 |
12 Jul1970 |
726 19 May 1969 |
Italy Treaty Protocol (Additional Protocol) |
24 April 1974 7 Oct 1980 4 Jun 2009 |
9 June 1983 |
1586 5 Sep 1980 4 Jun 1982 4125 4 Jun 2010 |
Kuwait (New Agreement) |
15 Dec 1984 5 Oct 2010 |
25 Sep 1986 |
2026 18 Jan 1985 |
Lebanon |
18 Feb 2003 |
14 Apr 2005 |
3976 8 Apr 2005 |
Malta |
22 Oct 1993 |
11 Aug 1994 |
2860 25 Feb 1994 |
Mauritius |
21 Jan 2000 |
12 Jun 2000 |
3410 2 Jun 2000 |
Norway |
2 May 1951 |
1 Jan 1955 |
11 Jun 1956 |
Poland |
4 Jun 1992 |
9 Jul 1993 |
2735 4 Sep1992 |
Romania |
16 Nov 1981 |
8 Nov 1982 |
1757 26 Feb 1982 |
Russia (Amendment Protocol) |
5 Dec1998 7 Nov 2010 |
17 Aug 1999 |
3306 26 Feb 1999 |
South Africa |
26 Nov 1997 |
8 Dec1998 |
3214 16 Jan 1998 |
Sweden |
22 Oct 1988 |
14 Nov1989 |
2377 20 Jan 1989 |
Syria |
15 Mar 1992 |
22 Feb 1995 |
2863 4 Mar 1994 |
Singapore |
24 Nov 2000 |
8 Feb 2001 |
3641 30 Dec 2000 |
Thailand |
27 Oct 1998 |
4 April 2000 |
3394 17 Mar 2000 |
United Kingdom Treaty Protocol |
20 Jun1974 2 Apr 1980 |
1 Nov1974 |
1107 5 Jul 1974 |
USA |
19 Mar 1984 |
31 Dec 1985 |
1944 4 April 1984 |
Serbia* |
29 Jun1985 |
8 Sep1986 |
2073 23 Aug1985 |
Montenegro* |
29 Jun1985 |
5 Nov 2008 |
2073 23 Aug1985 |
Slovenia* (New Agreement) |
29 Jun1985 12 Oct 2010 |
8 Sep 1986 |
2073 23 Aug1985 |
Slovakia** |
15 April 1980 |
30 Dec 1980 |
1599 3 May1980 |
Czech Republic** (new agreement) |
15 April1980 28 April 2009 |
30 Dec 1980 26 Nov 2009 |
1599 3 May1980 4114 13 Nov 2009 |
Azerbaijan*** |
29 Oct 1982 |
26 Aug 1983 |
26 Nov 1982 |
Armenia |
17 Jan 2011 |
Pending |
Pending |
Kyrgyzstan*** |
29 Oct 1982 |
26 Aug 1983 |
26 Nov 1982 |
Moldavia |
28 Jan 2008 |
03 Sept 2008 |
4098 29 Aug 2008 |
Tanzikistan*** |
29 Oct 1982 |
26 Aug 1983 |
26 Nov 1982 |
Uzbekistan*** |
29 Oct 1982 |
26 Aug 1983 |
26 Nov 1982 |
Ukraine*** |
29 Oct 1982 |
26 Aug 1983 |
26 Nov 1982 |
Seychelles |
28 Jun 2006 |
27 Oct 2006 |
25 Oct 2006 |
San Marino |
27 April 2007 |
18 July 2007 |
4088 13 July 2007 |
Qatar |
11 Nov 2008 |
20 Mar 2009 |
4099 14 Nov 2008 |
United Arab Emirates |
27 Feb 2011 |
Pending |
Pending |
Notes:
* The treaty between Cyprus and the Socialist Federal Republic of Yugoslavia is still in force.
** The treaty between Cyprus and the Czechoslovak Socialist Republic is still in force. The said treaty has ceased to apply between Cyprus and Czech Republic as from 1.1.2010, date of application of the provision of the new agreement.
***The treaty between Cyprus and the Union of Soviet Socialist Republics is still in force.
Full explanations of the various Double Tax Treaties with Cyprus can be found at the Cyprus Ministry of Finance, with downloadable PDFs,
click here
Cyprus Bilateral MoUs?
The Cyprus Securities and Exchange Commission has signed a multilateral Memorandum of Understanding with the regulatory authorities of the European Community Member States through the Committee of the European Securities Regulators. Bilateral MoUs also exist between Cyprus and the following national organisations:
- Australian Securities & Investments Commission
- Austrian Securities Authority
- Bundesanstalt für Finanzdienstleistungsaufsicht (BaFIN)-Germany
- Bulgarian Financial Supervision Commission
- Comissão do Mercado de Valores Mobiliários-Portugal
- Czech Securities Commission
- Egypt Capital Market Authority
- Hellenic Republic Capital Market Commission
- Hungarian Financial Supervisory Authority
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- Isle of Man Financial Supervision Commission
- Israel Securities Authority
- Jersey FAQ Answers Commission
- Malta Stock Exchange
- Polish Securities and Exchange Commission
- Romanian National Securities Commission
- Slovak Republic Financial Market Authority
- Dubai FAQ Answers Authority
- Federal Financial Markets Service of Russia
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