The
treaties currently concluded by Cyprus provide for withholding taxes on income
flows to Cyprus, as outlined in the table below. Cyprus offshore companies are
not required to withhold tax on payments made by them, therefore, no withholding
taxes table is included for these types of payments.
Witholding Tax
Rates: |
Notes
1.
Under Cyprus legislation the wihholding tax on dividends paid by a Cyprus local
company to a foreign company is fully refundable. In the absence of a treaty,
there is withholding tax of thirty percent on dividend payment to foreign individual
shareholders. If a treaty exists, its provisions prevail.
 2.
Twenty five percent on the excess amount on annual payments over CYP 100.000.
3. Five percent on film and TV royalties.
4. Zero if paid to a government
or for export guarantee.
5. Zero on literary, dramatic, musical or artistic
work.
6. Zero if paid to the government of the other state.
7.
For literary, artistic or scientific work, film, and TV royalties, the relevant
non-treaty rate applies.
8. Ten percent if received by a company controlling
twenty five percent or more of the voting power.
9. Ten percent if received
by a company controlling ten percent or more of the voting power.
10.
Zero if paid to a government, bank or financial institution.
11. Fifteen
percent if received by a company controlling less than twenty five percent of
the voting power.
12. The treaty provides for withholding taxes on dividends,
but Greece does not impose any withholding tax in accordance with its own legislation.
13. Five percent on film royalties.
14. Five percent if received by
a company controlling twenty five percent or more of the voting power.
15.
Zero if received by a company controlling fifty percent or more of the voting
power.
16. This rate applies to individual shareholders regardless of
their percentage of shareholding. Companies controlling less than ten percent
of the voting shares are also entitled to this rate.
 17.
Five percent if received by a company controlling ten percent or more of the voting
power.
18. The treaty provides for withholding taxes, but Hungary does not
impose any withholding taxes in accordance with its own legislation.
19.
Zero if received by a company controlling twenty five percent or more of the voting
power.
20. Fifteen percent for patent, trademarked, design or model, plan,
secret formula or process or any copy right or scientific work, or industrial,
commercial equipment or information.
21. Malta retains the right to tax
dividends at a rate not exceeding that paid by the company in question on the
profits out of which the dividends are distributed. This rate is currently thirty-five
percent.
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