New Double Tax Treaty Between Cyprus and Qatar
We note that as per Circular No. 2010/1 of the Cyprus Inland Revenue issued on 22 January 2010, the treaty between the Government of the Republic of Cyprus and the Government of the State of Qatar for the avoidance of double taxation signed on 11 November 2008 (the “Treaty”) and ratified in March 2009 has come into force as of 01 January 2010.
In summary, the withholding taxes under the Treaty are as follows:-
(a) Dividends: Nil
(b) Interest: Nil
(c) Royalties: 5%
It is noted that the royalty rate in paragraph (c) above is only relevant for payments made from Qatar to Cyprus. According to Cyprus legislation there is no withholding tax on payment of royalties when these are distributed out of Cyprus provided that:-
- the beneficial owner is not a Cyprus resident and
- the intellectual property right is used outside of Cyprus.
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