PAID TO RESIDENTS OF CYPRUS Country Dividends Interest Royalties Austria 10% nil nil Belgium 15% 15% nil Bulgaria nil nil nil Canada 15% 15% 10% (12) China 10% 10% 5% (8) C.I. S (Ex-USSR) nil nil nil Czech Republic 10% 10% 5% (8) Slovakia 10% 10% 5% (8) Denmark 10% (1) 10% nil Egypt 15% 15% 10% France 10% (2) 10% nil (10) Germany 15% (3) 10% nil (10) Greece 25% 10% nil (9) Hungary 15% (4) 10% (7) nil India 15% (2) 10% 10% Ireland nil nil nil (9) Italy nil 10% nil Kuwait 10% 10% (7) 5% (8) Malta 15 10 10 Norway 5% (5) nil nil Poland 10% 10% 5% Romania 10% 10% 5% (8) Sweden 5% (4) 10% (7) nil Syria 15% (16) 10 10% (17) United Kingdom 15% (6) 10% nil (10) United States 5% (13) 10% nil Former-Yugoslavia 10% 10% 10% Other Countries (15) (15) (15) PAID FROM CYPRUS TO NON RESIDENTS Country Dividends Interest Royalties Austria 10% (8) nil nil Belgium nil nil nil Bulgaria nil nil nil Canada 15% (8) 15% 10% (12) China 10% (8) 10% 10% (8) C.I. S (Ex-USSR) nil nil nil Czech Republic 10% (8) 10% 5% (8) Slovakia 10% (8) 10% 5% (8) Denmark 15% (8) 10% nil Egypt 15% (8) 15% 10% France 15% (8) 10% nil (10) Germany 15% (8) 10% nil (10) Greece 25% (8) 10% nil (9) Hungary 15% (8) 10% (7) nil India 15% (8) 10% 10% Ireland nil nil nil (9) Italy nil 10% nil Kuwait 10% (8) 10% (7) 5% (8) Malta 15% (8) 10% 10% Norway 25% (8) 25% nil Poland 10% (8) 10% 5% Romania 10% (8) 10% 5% (8) Sweden 15% (8) 10% (7) nil Syria 15%(16,8) 10% 10% (17) United Kingdom nil 10% nil United States nil 10% nil Former-Yugoslavia 10% (8) 10% 10% Other Countries 0-40% (14,8) 25% 10% (8) * The numbers in brackets refer to the explanatory notes.
EXPLANATORY NOTES
In all cases the income is taxable in the country of residence according to the Law of the country, tax credit being allowed for foreign tax.
(1) 10% if recipient is a company with at least 25% direct share interest (15% in all other cases).
(2) 10% if recipient is a company with at least 10% direct share interest (15% in all other cases).
(3) 10% if recipient is a company with at least 25% direct share interest. If recipient is a company with more than 25% direct or indirect share interest and the German corporation tax on distributed profits is lower than that on undistributed profits while the difference between the two rates is 15% or more, the rate is 27% (15% in all other cases).
(4) 5% if recipient is a company with at least 25% direct share interest (15% in all other cases).
(5) Nil if received by a company which controls, directly or indirectly, not less than 50% of the voting power.
(6) A resident of Cyprus other than a company which either alone or together with one or more associated companies controls directly or indirectly at least 10% of the voting power, is entitled to a tax credit in respect of the dividend. Where a resident of Cyprus is entitled to a tax credit, tax may also be charged on the aggregate of the cash dividend and the tax credit at a rate not exceeding 15%. In this case any excess tax credit is repayable. Where the recipient is not entitled to a tax credit, the cash dividend is exempt from any tax.
(7) Nil if received by Government institutions or by any person in respect of debts guaranteed or financed by Government or financial institutions wholly owned by the Government.
(8) According to the Cyprus Income Tax Law, companies are not taxed for income tax on dividends.
(9) 5% on cinematographic films not including television films.
(10) 5% on cinematographic films including films and video tapes for television.
(11) Nil if royalties are copyright and other literary, dramatic, musical or artistic work not including film or videotape royalties.
(12) 5% if recipient is a company with at least 10% direct share interest (15% in all other cases).
(13) According to the personal tax rates starting at nil for chargeable income up to C£2.000 and reaching 40% for income over C£8.000.
(14) There is a 30% withholding tax on dividends which is fully refundable to foreign corporation on application. The tax for individuals is restricted to the rates provided under the respective Tax Treaties as shown in the Table above.
(15) At the rate applicable in accordance with domestic law.
(16) Nil if received by a company which controls, directly or indirectly, not less than 25% of the voting power.
(17) 15% for patent, trademark, design or model, plan, secret formula or process or any copyright or scientific work, or industrial, commercial equipment or information.
(18) The Double Tax Treaty with Belgium has not been ratified
This information was correct in June 1997.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
