United States-Cyprus Tax Treaty
US- Cyprus Tax Treaty Quick Summary. The Republic of Cyprus is an island country in the Eastern Mediterranean Sea. An independent state since 1960, Cyprus is a unitary presidential republic.
Resident companies are subject to tax on worldwide income. Nonresident companies are taxed only on Cyprus-source income.
Cyprus has implemented the European Union (EU) Anti-Tax-Avoidance Directive (ATAD), and controlled foreign company (CFC) rules and general anti-abuse rules(GAAR) effective 2019. In addition, effective 2020, Cyprus has enacted an exit tax and hybrid mismatch rules.
Cyprus has adopted the Common Reporting Standard (CRS) on automatic exchange, as well as executed as intergovernmental agreement (IGA) with the United States under the Financial Account Tax Compliance Act (FATCA).
Cyprus is a member of the European Union.
U.S.-Cyprus Tax Treaty
Cyprus Tax Treaty.
- Convention between the Government of the United States of America and the Government of the Republic of Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (the Convention), together with a related exchange of notes, Nicosia on March 19, 1984
- TECHNICAL EXPLANATION OF THE CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE REPUBLIC OF CYPRUS FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME SIGNED AT NICOSIA ON MARCH 19, 1984
Currency. Euro (EUR)
Common Legal Entities. Public and private limited liability company, partnership and branches.
Tax Authority. Tax Department
Tax Treaties. Cyprus is party to 63 tax treaties and a signatory to the OECD’s MLI.
Corporate Income Tax Rate. Generally 12.5%, but vary depending upon the type of income.
Individual Tax Rate. Generally 17%, but vary depending upon the type of income.
Corporate Capital Gains Tax Rate. 20%
Individual Capital Gains Tax Rate. 20%
Residence. Companies are deemed to be tax residents if management and control is exercised in Cyprus.
Royalties. 10%, 5%
Transfer Pricing. Yes. Cyprus adopts a market value and arm’s-length standard.
CFC Rules. EU ATAD controlled foreign company provisions apply.
Hybrid Treatment. Yes, effective 2020.
Inheritance/estate tax. No.
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