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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
  • France
  • Germany
  • Greece
  • Hungary
  • Iceland
  • India
  • 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

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 1975

2011
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
  • 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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