YIOLA STAVRAKI
L.L.C.
ADVOCATES

DOUBLE TAX TREATIES TO WHICH CYPRUS IS A SIGNATORY

Cyprus has concluded a wide array of double tax treaties with various countries, as provided below:

As a result, offshore entities incorporated in Cyprus which enjoy a tax exemption in Cyprus will be able to benefit from the same tax exemption in the respective Treaty country.
  • Armenia*
  • Austria
  • Belarus
  • Belgium
  • Bulgaria
  • Canada
  • China
  • CIS (ex-USSR)
  • Czech Republic
  • Denmark
  • Egypt
  • Federal Republic of Germany
  • Finland*
  • France
  • Greece
  • Hungary
  • India
  • Ireland
  • Italy
  • Japan*
  • Kuwait
  • Lebanon
  • Malta
  • Mauritius
  • Norway
  • Poland
  • Quatar ***
  • Romania
  • Russia
  • Seychelles **
  • Singapore*
  • Slovakia
  • South Africa*
  • Sweden
  • Syria
  • Thailand
  • Ukraine
  • United Kingdom
  • United States
  • Serbia and Montenegro
  • The Treaty between Cyprus and Russia which was signed in December 1998 replaced the USSR (CIS) Treaty regarding Russia but not regarding the rest of the members of the CIS, which are still bound by the old treaty. The two treaties in question, however, are very similar.

  • * indicates that the treaty is still to be ratified

  • ** In July, 2006, the governments of Cyprus and the Seychelles agreed to a new bilateral pact targeted at preventing the double taxation of income

  • *** In November 2008, the Qatari Prime Minister Sheikh Hamad bin Jassim al Thani visited Nicosia to ratify several bilateral agreements and Memoranda of Understanding between Qatar and Cyprus, including an agreement on the avoidance of double taxation.

EXCHANGE OF INFORMATION BETWEEN THE CYPRUS TAX AUTHORITIES AND FOREIGN TAX AUTHORITIES

On July 25, 2008 the Ascertainment and Collection of Taxes Law of 1978 was amended by the Ascertainment and Collection of Taxes Law of 78(I) of 2008 (the “Law”) laying down revised principles governing the exchange of information relating to tax matters between Cyprus and foreign countries with which Cyprus has signed double tax treaties. The crucial provisions of the Law are as follows:

  • All confidentiality privileges other than legal privilege can be circumvented provided that the conditions of the Law are fulfilled.

  • The relevant foreign authority requesting information should provide the Cyprus Commissioner of Inland Revenue Department (the “Commissioner”) with specific details of the reasons for requesting such information.

  • The information is not provided if the requesting State does not have corresponding enabling provisions for the provision of information in its local legislation.

  • If the conditions in paragraphs (ii) and (iii) above are satisfied the Commissioner can obtain information from sources in Cyprus for the purpose of forwarding same to the requesting foreign authority.

  • Notwithstanding the above, the powers of the Commissioner may only be following the receipt of the written consent of the Attorney-General of the Republic. This is done on an ad hoc basis.