New Double Tax Treaty between Cyprus and the United Kingdom  
A new Double Tax Treaty (the “New DTT”) has been signed on 22 March 2018 between Cyprus and the United Kingdom (the “UK”) to strengthen and further develop the economic relations between the two countries. The New DTT will enter into force once ratified by each country. Once the New DTT will come into effect, it will replace the existing double tax treaty between Cyprus and the UK which was signed on 20 June 1974 (as amended by the 1980 protocol).
The main provisions of the New DTT are briefly outlined below:
The New DTT provides for 0% withholding tax on dividend payments provided that the recipient is the beneficial owner of the dividends.
However, if the dividends are paid by certain investment vehicles out of income derived directly or indirectly from tax exempt immovable property income, a 15% withholding tax applies.
Interest and Royalties
With respect to interest and royalty payments, a 0% withholding tax applies.
Capital gains
With respect to capital gains, Cyprus retains the exclusive taxing right on the disposal of shares made by Cyprus tax residents, except in the following cases:

1. Where the shares (other than shares in which there is substantial and regular trading on a Stock Exchange) derive more than 50% of their value directly or indirectly from immovable property situated in UK; or
2. Where the shares derive their value or the greater part of their value directly or indirectly from certain offshore rights/property relating to exploration or exploitation of the seabed or subsoil or their natural resources located in the UK.  

Limitation of Benefits
The New DTT includes a Limitation of Benefits clause in accordance with the OECD/G20 Base Erosion and Profit Shifting project Action 6 report “Principal Purpose Test” which is a minimum standard and provides that a double tax treaty benefit shall not be granted in the instance where the obtaining of that benefit was one of the principal purposes of the arrangement or transaction.
The full text of the New DTT and protocol can be found here.