Cyprus and Barbados have on 3 May 2017 signed a Double Tax Treaty (the “DTT
”) which will enhance the economic and trade relations between the two countries. The DTT will become effective on or after 1 January of the year following that in which all legal procedures are completed for the DTT to enter into force.
The DTT is generally based on the OECD Model Tax Convention framework and applies to taxes on income as well as on gains from alienation of movable or immovable property.
The DTT provides for 0% withholding tax
and royalty payments
With respect to capital gains
arising from the sale of shares in Barbados companies (including Barbados companies holding Barbados located immovable property) by Cyprus tax residents, the DTT provides that the exclusive taxing right remains with the alienator i.e. Cyprus. However, this is not the case where the value of the shares relates to certain offshore property with respect to the exploration or exploitation of the seabed or subsoil or natural resources of Barbados.
The full text of the treaty and protocol can be found here.