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Table B - Maximum WHT on inbound payments to Cyprus

Received in Cyprus
Paid from Dividends % Interest % Royalties %
Armenia 0/5 (1) 5 5
Austria 10 Nil Nil
Bahrain Nil Nil Nil
Barbados (45) Nil Nil Nil
Belarus 5/10/15 (2) 5 5
Belgium 10/15 (3) 0/10 (4), (5) Nil
Bosnia (6) 10 10 10
Bulgaria 5/10 (7) 0/7 (4), (8) 10 (8)
Canada
15 0/15 (9) 0/10 (10)
China, P.R.
10 10 10
Czech Republic
0/5 (11) Nil 0/10 (12)
Denmark
0/15 (4), (13) Nil Nil
Egypt
15 15 10
Ethiopia (46)
5 5 5
Estonia
Nil Nil Nil
Finland
5/15 (14) Nil Nil
France
10/15 (15) 0/10 (16) 0/5 (17)
Georgia
Nil Nil Nil
Germany
5/15 (18) Nil Nil
Greece
25 10 0/5 (19)
Guernsey
Nil Nil Nil
Hungary
5/15 (3) 0/10 (4) Nil
Iceland
5/10 (39) Nil 5
India
10 (20) 0/10 (46) 10 (21)
Iran (45)
5/10 (47) 5 6
Ireland, Rep. of
Nil Nil 0/5 (19)
Italy
15 10 Nil
Jersey (45)
Nil Nil Nil
Kuwait
0 0 5
Latvia
0/10(42) 0/10(42) 0/5(43)
Lebanon
5 5 Nil
Lithuania
0/5 (22) Nil 5
Malta
Nil 10 10
Mauritius Nil Nil Nil
Moldova 5/10 (24) 5 5
Montenegro (6)
10 10 10
Norway 0/15 (36) Nil Nil
Poland 0/5 (23) 0/5 (4) 5
Portugal 10 10 10
Qatar Nil Nil 5
Romania 10 0/10 (4) 0/5 (25)
Russia 5/10 (26) Nil Nil
San Marino Nil Nil Nil
Serbia (6) 10 10 10
Seychelles Nil Nil 5
Singapore Nil 0/7/10 (4), (27) 10
Slovak Republic(37) 10 0/10 (4 0/5 (25)
Slovenia 5 5 5
South Africa 5/10(41) Nil Nil
Spain 0/5 (28) Nil Nil
Sweden 5/15 (3) 0/10 (4) Nil
Switzerland 0/15 (40) Nil Nil
Syria 0/15 (29) 0/10 (9) 10/15 (38)
Thailand 10 10/15 (30) 5/10/15 (31)
Ukraine 5/15 (32) 2 5/10 (33)
United Arab Emirates Nil Nil Nil
United Kingdom
0/15 (34) 10 0/5 (17)
United States 5/15 (35) 0/10 (16) Nil

 

Notes

  1. The WHT rate of 5% applies where a dividend is paid by a company in which the beneficial owner has invested less than EUR 150.000.
  2. A WHT rate of 5% applies where the investment is not less than EUR 200.000 in the share capital of the company paying the dividend. If such investment is less than EUR 200000, dividends are subject to 15% WHT which is reduced to 10% if the recipient company controls 25% or more of the paying company.
  3. A WHT rate of 15% applies if received by a company holding less than 25% of the share capital of the paying company and in all cases if received by an individual.
  4. No WHT if paid to the government/Central Bank/ Public Authority of the other state.
  5. No WHT for interest on deposits with banking institutions.
  6. Serbia, Montenegro and Bosnia apply the Yugoslavia/Cyprus treaty.
  7. The WHT 5% rate applies to companies holding directly at least 25% of the share capital of the company paying the dividend. In all other cases the WHT is 10%.
  8. The treaty rates do not apply if the payment is made to a Cyprus entity by a resident of Bulgaria owning directly or indirectly at least 25% of the share capital of the Cyprus entity and the Cyprus entity pays tax in Cyprus at a tax rate lower than the usual tax rate.
  9. Nil if paid to a government/Central Bank/ Public Authority or for export guarantee.
  10. Nil on literary, dramatic, musical, or artistic work (but not including royalties in respect of motion picture films and works on film or videotape for use in connection with television).
  11. Nil applies if received by a company (excluding partnership) which holds directly at least 10% of the share capital of the paying company for an uninterrupted period of no less than one year. A WHT rate of 5% applies in all other cases.
  12. 10% WHT applies for patent, trademark, design or model, plan, secret formula or process, computer software or industrial, commercial or scientific equipment, or for information concerning industrial, commercial, or scientific experience.
  13. A WHT rate of 15% if received by a company controlling less than 10% of the share capital of the paying company or the duration of any holding is less than one uninterrupted year. A WHT rate of 15% also applies if received by an individual.
  14.  A WHT rate of 15% applies if received by a company controlling less than 10% of the voting power in the paying company and in all cases if received by an individual.
  15. A WHT rate of 15% if received by a company (partnership is excluded) holding less than 10% of the capital of the paying company and in all cases if received by an individual.
  16. Nil if paid to a government, bank, or financial institution.
  17. A WHT rate of 5% on royalties for cinematographic films including films and video tapes for television.
  18. A WHT rate of 15% if received by a company holding less than 10% of the capital of the paying company and in all cases if received by an individual.
  19. A WHT rate of 5% on cinematographic film royalties (other than films shown on television).
  20. Prior to 1 April 2017, the applicable WHT rate is 15% if received by a company holding less than 10% of the shares of the paying company and in all cases if received by an individual.
  21. A WHT rate of 10% is also applicable for payments of a technical, managerial, or consulting nature. Prior to 1 April 2017, a rate of 15% applies on royalties.
  22. A WHT rate of 5% if received by a company (other than partnership) holding less than 10% of the capital of the company paying the dividend and in all cases if received by an individual.
  23. Nil rate applies if the recipient company (partnership is excluded) holds directly 10% of the share capital of the paying company for an uninterrupted period of at least 2 years. 5% in all other cases.
  24. A WHT rate of 5% applies if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends. 10% in all other cases.
  25. 5% WHT rate applies for patents, trademarks, designs or models, plans, secret formulas, or processes, or any industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience.
  26. A WHT rate of 10% on dividend if paid by a company in which the beneficial owner has invested less than EUR 100.000 in the share capital of the company paying the dividend.
  27. A WHT rate of 7% if paid to a bank or financial institution.
  28. A WHT rate of 5% if received by a company holding less than 10% of the capital of the paying company and in all cases if received by an individual or a company not limited at least partly by shares.
  29. A WHT rate of 15% if received by a company holding less than 25% of the share capital of the paying company and in all cases if received by an individual or a company not limited at least partly by shares.
  30. A WHT rate of 10% on interest received by a financial institution or when it relates to sale on credit of any industrial, commercial, or scientific equipment or of merchandise.
  31. A WHT rate of 5% applies for any copyright of literary, dramatic, musical, artistic, or scientific work. A WHT 10% rate applies for industrial, commercial, or scientific equipment. A 15% rate applies for patents, trade marks, designs or models, plans, secret formulas, or processes.
  32. A WHT rate of 15% if a dividend is paid by a company in which the beneficial owner holds less than 20% of the share capital of the paying company and the beneficial owner has invested less than 100.000 Euro.
  33. A WHT 5% WHT will be levied on payment of royalties in respect of any copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience. 10% WHT will be levied in all other cases.
  34. A WHT rate of 15% applies to individual shareholders regardless of their percentage of shareholding. Companies controlling less than 10% of the voting shares are also entitled to a rate of 15%. Companies controlling at least 10% of the voting shares are entitled to nil WHT.
  35. A WHT rate of 15% if received by a company controlling less than 10% of the voting power of the paying company and in all cases if received by an individual. If a company controls at least 10% of the voting power of the paying company in order to benefit from the WHT rate of 5% other conditions relating to the income of the paying company need to be satisfied, otherwise a WHT rate of 15%.
  36. Nil rate applies if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends or if the beneficial owner of the shares is the Government of Cyprus or Norway. A WHT rate of 15% in all other cases.
  37. The Cyprus - Czechoslovakia treaty applies with the Slovak Republic.
  38. 10% WHT rate applies on payment of royalties of any copyright of literary, artistic or scientific work including cinematograph films, and films or tapes for television or radio broadcasting. A rate of 15% applies on payments of royalties of any patent, trade mark, design or model, plan, secret formula or process, or any industrial, commercial, or scientific equipment, or for information concerning industrial, commercial or scientific experience.
  39. A WHT rate of 5% if received by company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividend. 10% in all other cases.
  40. Nil rate applies if the beneficial owner is a company (other than a partnership) which holds directly at least 10 per cent of the capital of the company paying the dividends during an uninterrupted period of at least one year (the holding period condition may be satisfied post the date of the dividend payment). Nil rate also applies if the beneficial owner is a pension fund or other similar institution or relates to the Government of Cyprus or Switzerland. 15% in all other cases.
  41. A protocol to the treaty entered into force on 18 September 2015 but may apply retrospectively. 5% WHT rate applies if the beneficial owner is a company which holds at least 10% of the capital of the company paying the dividend. 10% in all other cases.
  42. Nil applies if the payer is a company that is a resident in Latvia and the beneficial owner of the income is a company (other than partnership) that is a resident in Cyprus. 10% rate applies for all other cases (except for certain governmental interest).
  43. Nil applies if the payer is a company that is a resident in Latvia and the beneficial owner of the income is a company (other than partnership) that is a resident in Cyprus. 5% rate applies for all other cases.
  44. Nil if paid to a government or any other institution agreed upon between the two States. Prior to 1 April 2017, nil rate also applies if paid to a bank or financial institution.
  45. The treaty is effective as from 1 January 2018.
  46. The treaty is effective as from 8 July 2018 for Ethiopia.
  47. The WHT rate of 5% applies if the beneficial owner of the dividends holds directly at least 25% of the capital of the company paying the dividends.

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