The double tax treaties (the "
DTTs”) which Cyprus has concluded with Ethiopia, Iran and Jersey have recently entered into force and, as per the provisions of the relevant DTTs, will become effective as from 1 January 2018.
In brief:
1. The DTT between Cyprus and Ethiopia provides for
5% withholding tax on dividends, interest and royalties.
2. The DTT between Cyprus and Iran provides for
5% withholding tax on dividends if the beneficial owner is a company (other than partnership) which holds directly at least 25% of the capital of the company paying the dividends and
10% withholding tax in all other cases. The DTT also provides for a withholding tax of
5% on interest and
6% on royalties.
3. The DTT between Cyprus and Jersey provides for
0% withholding tax on dividends, interest and royalties.
The full list of DTTs concluded between Cyprus and other countries can be found
here.