The following tables give a summary of the withholding taxes (WHT) provided by the double tax treaties entered into by Cyprus. Note that there is no withholding tax on dividends and interest paid to non-residents of Cyprus at all times thus the treaty rates shown below are NOT applicable.
PAID TODIVIDENDS (1)
%
INTEREST (1)
%
ROYALTIES
%
Non-treaty countriesNilNilNil (2)
ArmeniaNil (30)55
Austria10NilNil
Belarus5 (17)55
Belgium10 (8)10 (6,18)Nil
Bulgaria5 (22)7 (6)10
Canada1515 (4)10 (5)
China, P.R.101010
Czech RepublicNil (28)NilNil (29)
DenmarkNil (6, 32)NilNil
Egypt151510
EstoniaNilNilNil
Finland5 (35)NilNil
FranceNil10 (10)Nil (3)
Germany5 (36)NilNil
Greece2510Nil (11)
HungaryNil10 (6)Nil
India10 (37)10 (10)10 (15)
IrelandNilNilNil (11)
ItalyNil10Nil
Kuwait1010 (6)5 (7)
Lebanon55Nil
Malta151010
MauritiusNilNilNil
Moldova5 (26)55
Montenegro (25)101010
NorwayNilNilNil
PolandNil (34)5 (6)5
Portugal101010
QatarNilNil5 (27)
Romania1010 (6)5 (7)
Russia5 (16)NilNil
San MarinoNilNilNil
Serbia (25)101010
SeychellesNilNil5
SingaporeNil10 (6,24)10
Slovakia1010 (6)5 (7)
Slovenia5 (31)55
South AfricaNilNilNil
Sweden5 (8)10 (6)Nil
SyriaNil (8)10 (4)10
Thailand1015 (20)5 (21)
Ukraine5 (19)25 (33)
United KingdomNil10Nil (3)
United StatesNil10 (10)Nil
RECEIVED FROMDIVIDENDS
%
INTEREST
%
ROYALTIES
%
ArmeniaNil (30)55
Austria10NilNil
Belarus5 (17)55
Belgium10 (8)10 (6,18)Nil
Bulgaria5 (22)7 (6,23)10 (23)
Canada1515 (4)10 (5)
China, P.R.101010
Czech RepublicNil (28)NilNil (29)
DenmarkNil (6,32)NilNil
Egypt151510
EstoniaNilNilNil
Finland5(35)NilNil
France10 (36)10 (10)Nil (3)
Germany5 (36)NilNil
Greece2510Nil (11)
Hungary5 (8)10 (6)Nil
India10 (37)10 (10)15 (14)
IrelandNilNilNil (11)
Italy1510Nil
Kuwait1010 (6)5 (7)
Lebanon55Nil
MaltaNil1010
MauritiusNilNilNil
Moldova5 (26)55
Montenegro (25)101010
NorwayNil (12)NilNil
PolandNil (34)5 (6)5
Portugal101010
QatarNilNil5 (27)
Romania1010 (6)5 (7)
Russia5 (16)NilNil
San MarinoNilNilNil
Serbia (25)101010
SeychellesNilNil5
SingaporeNil10 (6,24)10
Slovakia1010 (6)5 (7)
Slovenia5 (31)55
South AfricaNilNilNil
Sweden5 (8)10 (6)Nil
SyriaNil (8)10 (4)10
Thailand1015 (20)5 (21)
Ukraine5 (19)25 (33)
United Kingdom15 (13)10Nil (3)
United States5 (9)10 (10)Nil

Under Cyprus legislation there is never any WHT on dividends and interest paid to non-residents of Cyprus.

Royalties earned on rights used within Cyprus are subject to WHT of 10%.

A rate of 5% on film and TV royalties.

Nil if paid to a government/Central Bank/ Public Authority or for export guarantee.

Nil on literary, dramatic, musical, or artistic work.

Nil if paid to the government/Central Bank/ Public Authority of the other state.

This rate applies for patents, trademarks, designs or models, plans, secret formulas, or processes, or any industrial,  commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience.

A rate of 15% if received by a company holding less than 25% of the share capital of the paying company and in all cases if received by an individual.

A rate of 15% if received by a company controlling less than 10% of the voting power of the paying company and in all cases if received by an individual. If a company controls at least 10% of the voting power of the paying company in order to benefit from the WHT rate of 5% other conditions relating to the income of the paying company need to be satisfied, otherwise a WHT rate of 15%.

Nil if paid to a government, bank, or financial institution.

A rate of 5% on film royalties.

A rate of 5% if received by a company controlling less than 50% of the voting power and in all cases if received by an individual.

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. Companies controlling at least 10% of the voting shares are entitled to nil WHT.

A rate of 10% for payments of a technical, managerial, or consulting nature.

Treaty rate is 15%. However, the maximum WHT per Cyprus tax legislation is 10% (refer to note 2).

A rate of 10% on dividend if paid by a company in which the beneficial owner has invested less than EUR100.000 in the share capital of the company paying the dividend.

If investment is less than EUR 200,000, dividends are subject to 15% WHT which is reduced to 10% if the recipient company controls 25% or more of the paying company.

No WHT for interest on deposits with banking institutions.

A rate of 15% if a dividend is paid by a company in which the beneficial owner holds less than 20% of the share capital of the paying company and the beneficial owner has invested less than Eur 100,000.

A 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.

This rate applies for any copyright of literary, dramatic, musical, artistic, or scientific work. A 10% rate applies for industrial, commercial, or scientific equipment. A 15% rate applies for patents, trade marks, designs or models, plans, secret formulas, or processes.

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 WHT is 10%.

This rate does not apply if the payment is made to a Cyprus international business entity by a resident of Bulgaria owning directly or indirectly at least 25% of the share capital of the Cyprus entity.

A rate of 7% if paid to a bank or financial institution.

Serbia, and Montenegro apply the Yugoslavia/Cyprus treaty.

This rate applies if received by a company (excluding partnerships) that holds directly 25% of the shares. A rate of 10% applies in all other cases.

Applies to any consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films and films, tapes or discs for radio or television broadcasting), computer software, any patent, trademark, design or model, plan, secret formula or process, or for information concerning industrial, commercial, or scientific experience.

This rate applies if received by a company (excluding partnership) which holds directly at least 10% of the share capital of the paying company for an uninterrupted period of no less than one year. 5% applies in all other cases.

10% for patent, trademark, design or model, plan, secret formula or process, computer software or industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience.

A rate of 5% if a dividend is paid by a company in which the beneficial owner has invested less than EUR 150,000.

The provisions of the Parent-Subsidiary EU directive are applicable.

A rate of 15% if received by a company controlling less than 10% of the share capital of the paying company or the duration of any holding is less than one uninterrupted year. A rate of 15% also applies if received by an indivdual.

A 5% WHT will be levied on payment of royalties in respect of any copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience. 10% WHT will be levied in all other cases.

This rate applies if the recipient company (partnership is excluded) holds directly 10% of the share capital of the paying company for an uninterrupted period of atleast 2 years. 5% in all other cases.

A rate of 15% applies if received by a company controlling less than 10% of the voting power in the paying company and in all cases if received by an individual.

A rate of 15% if received by a company holding less than 10% of the share capital of the paying company and in all cases if received by an individual.

A rate of 15% if received by a company holding less than 10% of the shares of the paying company and in all cases if received by an individual.