Cyprus double tax treaties.
65+ countries. One of Europe's widest networks. Cyprus has double tax treaties with over 65 countries — covering preferential withholding rates, tie-breaker residency rules and mutual agreement procedures. The network is a key reason Cyprus is chosen as a holding and IP jurisdiction.
The short answer
Cyprus has double tax treaties with over 65 countries. A treaty decides which country may tax each kind of income, can cut withholding tax on dividends, interest and royalties, and settles dual residency through tie-breaker rules; where both countries tax the same income, a credit removes the double charge.
- Treaty network
- 65+ countries
- Corporate tax
- 15%
- Non-dom dividends
- 0%
Cyprus tax treaty network visualized
Hover over countries to explore treaty details, withholding rates, and coverage specifics.
| Country | Dividend WHT | Interest WHT | Royalty WHT | Notes |
|---|---|---|---|---|
| UK | 0–15% | 10% | 0% | 0% with EU directive |
| Germany | 5–15% | 0% | 0% | 5% if 25%+ holding |
| USA | 5–15% | 10% | 0% | Most favoured nation |
| France | 10–15% | 10% | 0% | — |
| India | 10% | 10% | 10% | Popular routing vehicle |
| China | 10% | 10% | 10% | — |
| UAE | 0% | 0% | 0% | Full exemption |
| Israel | 0–15% | 10% | 0% | — |
| Singapore | 0% | 7% | 10% | — |
| Canada | 15% | 15% | 0–10% | — |
| Russia | Suspended | Suspended | Suspended | Suspended Aug 2023 |
Lower WHT on cross-border income
Treaties reduce the withholding tax that the source country can charge on dividends, interest and royalties paid to Cyprus recipients — allowing more income to flow to Cyprus at lower tax cost.
Resolve dual residency
Where an individual or company could be resident in both Cyprus and another country, the treaty tie-breaker rules determine which country has primary taxing rights — protecting against double taxation.
Resolve cross-border disputes
Where two countries' tax authorities disagree on how to apply a treaty, the MAP allows them to negotiate a binding resolution — protecting taxpayers from being taxed twice on the same income.
Why the treaty network matters
Cyprus's extensive double tax treaty network is one of its most valuable tax attributes. For holding companies distributing dividends from operating subsidiaries, the treaty network determines how much withholding tax is deducted at source — directly impacting the economics of the structure.
For example, a Cyprus holding company receiving dividends from an Indian subsidiary benefits from a 10% WHT rate under the India-Cyprus treaty — compared to India's domestic rate of 20% for non-treaty countries. On €1M of dividends, this saves €100,000 in Indian tax.
Cyprus benefits from EU directives that go beyond the treaty network. The Parent-Subsidiary Directive eliminates withholding tax on dividends paid between EU group companies. The Interest and Royalties Directive eliminates WHT on intercompany interest and royalties within the EU. These directives apply regardless of whether a bilateral treaty exists.
Planning a cross-border structure using Cyprus treaties?
Ask Taxerly about treaty routing, withholding tax planning, EU directives and holding company structures optimised for your jurisdictions.
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