|
Notes: |
| 1 |
Under Cyprus legislation there is no withholding tax
on Dividends, Interest and Royalties paid to non-residents of the
Republic of Cyprus. |
| 2 |
In case where Royalties are earned on rights used
within the Republic of Cyprus, there is withholding tax at the rate of
10%. |
| 3 |
On Films and Television Royalties there is
withholding tax at the rate of 5%. |
| 4 |
Zero withholding of tax if paid to a Government or
for export guarantee. |
| 5 |
Zero withholding of tax on Literary, Dramatic,
Musical or Artistic work. |
| 6 |
Zero withholding of tax if paid to the Government of
the other State. |
| 7 |
This rate applies for Patents, Secret formulae or
Processes, Trademarks, Designs or Models, Plants or any Industrial,
Commercial or Scientific equipment or for Information concerning
Industrial, Commercial or Scientific experience. |
| 8 |
Withholding tax at the rate of 5% if received by a
company controlling less than 25% of the voting power. |
| 9 |
Withholding tax at the rate of 5% if received by a
person controlling less than 10% of the voting power. |
| 10 |
Zero withholding of tax if paid to a Government, Bank
or Financial Institution. |
| 11 |
The treaty provides for withholding taxes on
Dividends but Greece does not impose any withholding tax in accordance
with its own legislation. |
| 12 |
Withholding tax at the rate of 5% on Film Royalties. |
| 13 |
Withholding tax at the rate of 5% if received by a
person controlling less than 50% of the voting power. |
| 14 |
This rate applies to individual shareholders
regardless of their percentage of shareholding. Companies controlling
less than 10% of the voting shares are also entitled to this rate. |
| 15 |
Withholding tax at the rate of 10% for payments of a
Technical, Managerial or Consulting nature. |
| 16 |
Treaty rate 15% therefore restricted to Cyprus
legislation rate. |
| 17 |
Withholding tax at the rate of 10% if Dividend paid
by a company in which the beneficial owner has invested less than
US$100.000. |
| 18 |
If investment is less than
200.000, Dividends
are subject to 15% tax withholding, which is reduced to 10% if the
recipient company controls 25% or more of the paying company. |
| 19 |
Zero withholding of tax for Interest on deposits with
banking institutions |
| 20 |
Armenia, Azerbaijan, Kurghystan, Moldova, Tatzikistan,
Uzbekistan and Ukraine apply the USSR – Cyprus treaty. |
| 21 |
Withholding tax at the rate of 10% on Interest
received by a financial institution or when it relates to sale on credit
of any Industrial, Commercial or Scientific equipment or of Merchandise. |
| 22 |
This rate applies for any Copyright of Literacy,
Dramatic, Musical, Artistic or Scientific work. A 10% rate applies for
Patents, Trade Marks, Designs or Models, plans, Secret formulae or
Processes. |
| 23 |
This rate applies to companies holding directly at
least 25% of the share capital of the company paying the dividend. In
all other cases the withholding tax is 10%. |
| 24 |
This rate does not apply if the payment is made to a
Cyprus International Business Entities by a resident of Bulgaria owing
directly or indirectly at least 25% of the share capital of the Cyprus
entity. |
| 25 |
Withholding tax at the rate of 7% if paid to bank or
financial institution. |
| 26 |
Slovenia and Serbia/Montenegro apply the Yugoslavia –
Cyprus treaty. |
