DT5354 | Double Taxation Relief Manual: Cyprus: Notes

Geographical scope

The UK considers that the convention covers the whole of the Island of Cyprus.

Dual-resident companies (Article 4(4))

The corporate residence tie-breaker at Article 4(4) follows a new approach where dual residence is determined by the competent authorities of the UK and Cyprus. This paragraph is to be read in conjunction with the guidelines set out in the Protocol.

Students (Article 19)

Visiting students, or business apprentices from Cyprus are exempt from UK tax on payments from abroad for the purpose of their maintenance, education or training.

Government service pensions (Article 18)

The 2018 Convention changes the way that government service pensions are taxed, so that from 1 January 2019, UK government pensions paid to residents of Cyprus who are not Cypriot nationals, are taxable solely in the UK. The 2018 Protocol allows affected taxpayers to elect to retain benefits under the 1974 Convention for a period of up to 5 years.