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Double Tax Treaties
The following tables give a summary of the withholding taxes:

    Received in Cyprus (%) Paid from Cyprus (%)
    Dividends Interest Royalties Dividends Interest Royalties
  Non-treaty countries N/a N/a N/a Nil Nil Nil (*)
  Treaty countries:            
1 Armenia 0 5 (31) 5 0 5 (31) 0
2 Austria 10 Nil Nil 10 Nil Nil
3 Belarus 10 (1+20) 5 5 10 (1+20) 5 5
4 Belgium 10 (1) 10 (14) Nil 10 (1) 10 Nil
5 Bulgaria 10 (24) 7(25) 10 (25) 10(24) 7 10
6 Canada 15 15(7) 10(12) 15 15(7) 10 (12)
7 China P. R. 10 10 10 10 10 10
8 CIS (**) (c) Nil Nil Nil Nil Nil Nil
9 Czech Republic Nil (29) Nil Nil Nil Nil 10 (30)
10 Denmark Nil (33) Nil Nil Nil (33) Nil Nil
11 Egypt 15 15 10 15 15 10
12 Estonia Nil Nil Nil Nil Nil Nil
13 Finland 5 (13) Nil Nil 5(13) Nil Nil
14 France (c) 10 (2) 10 (11) Nil (10) Nil 10 (11) Nil (10)
15 Germany 15 (3) 10 (15) Nil (10) Nil 10 (15) Nil (10)
16 Greece Nil (26) 10 Nil (9) Nil (26) 10 Nil (9)
17 Hungary 5 (4) 10 (15) Nil Nil 10(15) Nil
18 India 10 (2) 10 (15) 15 10 (2) 10(15) 15
19 Ireland (c) Nil Nil Nil (9) Nil Nil Nil (9)
20 Italy (c) 15 10 Nil Nil 10 Nil
21 Kuwait 10 10 (15) 5 (8) 10 10(15) 5 (8)
22 Lebanon 5 5 (14) Nil 5 5 (14) Nil
23 Malta Nil 10(15) 10 15 10(15) 10
24 Mauritius Nil Nil Nil Nil Nil Nil
25 Moldova 5(24) Nil (28) Nil (28) 5(24) Nil (28) Nil (28)
26 Norway (c) 5 (5) Nil Nil Nil Nil Nil
27 Portugal 10 10 10 10 10 10
28 Poland Nil (37) 5 5 Nil (37) 5 5
29 Qatar Nil Nil Nil (28) Nil Nil Nil (28)
30 Romania 10 10(15) 5 (8) 10 10(15) 5 (8)
31 Russia 10 (18) Nil Nil 10 (18+19) Nil Nil
32 San Marino Nil Nil Nil Nil Nil Nil
33 Seychelles Nil Nil Nil (28) Nil Nil Nil (28)
34 Singapore Nil 10 (23) 10 Nil 10 (23) 10
35 Slovakia 10 10(15) 5 (8) Nil 10 (15) 5 (8)
36 Slovenia 5 5 (32) 5 5 5 (32) 5
37 South Africa Nil Nil Nil Nil Nil Nil
38 Spain Nil (29) Nil Nil (36) Nil (29) Nil Nil (36)
39 Sweden 5 (4) 10(15) Nil 5 (4) 10 (15) Nil
40 Syria 15 (16) 10(15) 10 (17) 15 (16) 10 (15) 10 (17)
41 Thailand 10 10 (21) 5 (22) 10 10 (21) 5 (22)
42 Ukraine 5 (34) 2 5 5 (34) 2 5
43 United Arab Emirates 0 0 0 0 0 0
44 United Kingdom 15 (6) 10 Nil (10) Nil 10 Nil (10)
45 United States 5 (13) 10 (27) Nil Nil 10 (27) Nil
46 Yugoslavia (***) (c) 10 10 10 Nil 10 10

(*) Payment of dividends and interest from Cyprus to non-residents is exempt from any withholding tax. Royalty payments arising from rights used within the Republic is subject to withholding tax at 10%, whilst royalties from film and television rights used within the Republic by a non-resident is subject to withholding tax at 5%.
(**) CIS includes Azerbaijan, Kyrgyzstan, Tajikistan and Uzbekistan and excludes Kazakhstan.
(***) Yugoslavia includes Serbia and Montenegro.

Treaties with the following countries have reached the following stage:
(a) Negotiations in progress: Algeria, Bangladesh, Indonesia, Latvia, Libya, Lithuania, Luxembourg, Malaysia, Netherlands, Slovenia and Sri Lanka.
(b) Negotiations will commence soon: Brazil, Gabon, Georgia, Iran, Jordan, Morocco, Pakistan, and Vietnam.
(c) Negotiations for revision of existing agreements: France, Ireland, Italy, Kazakhstan, Norway and Yugoslavia.

Notes:
(1) 10% if recipient is a company with at least 25% direct share interest; 15% in all other cases
(2) 10% if recipient is a company with at least 10% direct share interest; 15% in all other cases
(3) 10% if recipient is a company with at least 25% direct share interest; 27% if recipient is a company with more than 25% direct or indirect share interest as long as the German corporate tax on distributed profits is lower than that on undistributed profits and the difference between the two rates is 15% or more; 15% in all other cases
(4) 5% if recipient is a company with at least 25% direct share interest; 15% in all other cases
(5) Nil if received by a company which controls, directly or indirectly, at least 50% of the voting power
(6) A resident of Cyprus, other than a company which either alone or together with one or more associated companies controls directly or indirectly at least 10% of the voting power, is entitled to a tax credit in respect of the dividend. Where a resident of Cyprus is entitled to a tax credit, tax may also be charged on the aggregate of cash dividend and the tax credit at a rate not exceeding 15%. In this case any excess tax credit is repayable, Where the recipient is not entitled to a tax credit, the cash dividend is exempt from any tax.
(7) Nil if paid to the government or as an export guarantee
(8) Nil if royalties are on literary, artistic or scientific work including cinematography films and films or tapes for television or radio broadcasting.
(9) 5% on cinematography films not including television films.
(10) 5% on cinematography films including television films.
(11) Nil if paid, to the government or other government body, in connection with the sale on credit of any industrial, commercial or scientific equipment or in connection with the sale of any merchandise by one enterprise to another enterprise or on any loan of whatever kind granted by a bank or guaranteed by the government or other statutory body
(12) Nil if royalties are copyright or other literary, dramatic, musical or artistic work not including film or videotape royalties.
(13) 5% if recipient is a company with at least 10% direct share interest; 15% in all other cases
(14) Nil if paid to the Government, political subdivision or a local authority, the National Bank or any other institution the capital of which is wholly owned by the Government or the political subdivision or the local authority or for interest on deposits not represented by bearer instruments with a banking enterprise.
(15) Nil if paid to the government, bank or financial institution
(16) Nil if shareholder is a company that holds directly at least 25% of the capital of the company paying the dividends; 15% in all other cases.
(17) 15% for any patent, trade mark, design or industrial, commercial, or scientific equipment or information concerning industrial, commercial scientific experience.
(18) 5% of the gross dividend where the direct investment in the capital of the paying company is the equivalent of €100,000.
(19) Nil if the recipient is a company.
(20) 5% if the beneficial owner has invested not less than €200,000 in the share capital of the paying company.
(21) 10% if it is received by any financial institution (including insurance), or is paid in connection with the sale on credit of any industrial, commercial or scientific equipment or is paid in connection with the sale on credit of any merchandise by one enterprise to another enterprise; 15% in all other cases.
(22) 5% on copyright of literary, dramatic, musical, artistic, or scientific work, including software, cinematography films or films or tapes used for radio or television broadcasting; 10% on industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific expertise; 15% on patent, trade marks, design or model, plan, secret formula or process.
(23) 7% if it is received by a bank or similar financial institution
(24) 5% if recipient is a company owning at least 25% of the capital of the paying company
(25) Nil if it is paid to a resident of Cyprus by resident of Bulgaria and at least 25% of the capital of the Cypriot resident is owned directly or indirectly by the Bulgarian resident
(26) The treaty provides for 25% but local legislation states Nil.
(27) Nil if paid to the government, bank or financial institution or in relation to amounts due from sale of property or provision of services or amounts due on loans guaranteed or secured by the government.
(28) May be taxed but shall not exceed 5% of the gross amount of the royalties/interest (whichever it applies)
(29) Nil if the beneficial owner is a company (other than partnership) which holds directly or indirectly at least 10% of the capital of the dividend paying company where such holding is held for an uninterrupted period of no less than one year; 5% in all other cases.
(30) Shall not exceed 10% in the case only of patent, trade mark, design or model, plan, secret formula or process, computer software or industrial, commercial, or scientific equipment or for information concerning industrial, commercial scientific experience.
(31) 5% if the beneficial owner has invested in the capital of the company less than the equivalent of €150.000 at the time of the investment.
(32) Nil if paid to the Government or to the local authority, or to the Central Bank.
(33) Nil if the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends, where such holding is being possessed for an uninterrupted period of no less than 12 months. Nil if the beneficial owner is the other Contracting State or the Central Bank of that other State, or any national agency or any other agency (including a financial institution) owned or controlled by the Government of that other State. Nil if the beneficial owner is a pension fund or other similar institution providing pension schemes in which individuals may participate in order to secure retirement benefits, where such pension fund or other similar institution is established, recognized for tax purposes and controlled in accordance with the laws of that other State. 15% in all other cases.
(34) Provided beneficial owner holds at least 20% of the capital of the dividend paying company or has invested in the acquisition of shares or other rights of the dividend paying company of at least €100,000. In all other cases the withholding tax rate is 15%.
(35) The withholding tax rate on royalties in respect of any copyright of scientific work, any patent, trade mark, secret formula, process or information concerning industrial, commercial or scientific experience is 5%, and 10% in all other cases
(36) Nil withholding tax applies with respect to copyrights of literary, artistic or scientific work including films, any patent, trademark, secret formula or process or for information concerning industrial, commercial or scientific experience
(37) Nil if the shareholder company owns at least 10% of the share capital of the company distributing the dividends and 5% in all other cases
"AuditPro Services" refers to AuditPro Services Ltd, a limited liability company registered in the Republic of Cyprus Reg. No. 155999
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