SolvedDT5353 | Double Taxation Relief Manual: Cyprus: Treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Cyprus are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty can be found on gov.uk.
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 0% | 10 |
| Dividends on direct investments | 0% | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a resident of the UK | 10 |
| Property income dividends | 15% (Note 1) | 10 |
| Interest | 0% | 11 |
| Royalties | 0% | 12 |
| Government pensions | Taxable only in the UK (note 2) | 18 |
| Other pensions | Taxable only in Cyprus unless the individual is a resident, and national of, the UK | 17 |
| Arbitration | Yes | 25 |
Note 1: Dividends paid out of income derived directly or indirectly from immovable property, where the beneficial owner of the dividends is a pension scheme established in Cyprus, shall be exempt from tax in the UK.
Note 2: The 2018 Protocol amends the Entry into Force provision of the 2018 Convention so that a person in receipt of a government service pension as at 18 July 2018 can elect for that pension to continue to be taxed in accordance with the provisions of the 1974 Convention for a period of up to 5 years ending on or before 31 December 2024.