Cyprus double tax treaties — rates and planning guides by country

The Cyprus-UK double tax treaty is one of the most used in Cyprus tax planning. It provides 0% withholding on royalties and 0% on dividends for qualifying holding companies, making Cyprus the natural holding and IP location for UK businesses.

The Cyprus-Israel double tax treaty is central to planning for the thousands of Israeli founders and investors who have relocated to Cyprus. With 0% royalty withholding and 5% dividend withholding for qualifying holdings, it enables efficient profit extraction from Israeli operations.

The Cyprus-Russia DTA was suspended by Russia in 2023. Companies with existing Russia-Cyprus structures should seek current specialist advice. Historically, this was one of the most heavily used bilateral treaties.

The Cyprus-Germany DTA provides 0% withholding on royalties, making it a strong basis for Cyprus IP holding structures serving German customers. German anti-avoidance rules require genuine Cyprus substance.

The Cyprus-India double tax treaty provides a 10% withholding rate on royalties and dividends, making Cyprus an efficient jurisdiction for holding companies investing in India and for IP licensing to Indian subsidiaries.

The Cyprus-UAE double tax treaty provides zero withholding on dividends, interest, and royalties between the two jurisdictions, supporting businesses that operate across both the UAE and Cyprus.

The Cyprus-France DTA provides 0% royalty withholding and reduced dividend rates, suitable for IP and holding structures involving French operations — with genuine substance required to withstand French anti-abuse scrutiny.

The Cyprus-Netherlands DTA is used in complex international structures where Cyprus and Netherlands entities cooperate. Zero WHT on royalties and interest, combined with 0% dividends for qualifying holdings.

The Cyprus-Ireland DTA provides zero withholding on all payment types. With both jurisdictions at low corporate rates, this treaty is used in specific international structures rather than for rate arbitrage.

The Cyprus-Poland DTA provides favourable 5% WHT on royalties, interest, and qualifying dividends — significantly below Polish domestic withholding rates and useful for Cyprus-based businesses with Polish operations or customers.

The Cyprus-Romania DTA provides a 5% withholding rate on royalties — one of the most useful provisions for Cyprus companies licensing IP into Romanian operations.

The Cyprus-China DTA provides 10% withholding on dividends, interest, and royalties. China applies strict beneficial ownership tests, so genuine substance in Cyprus is essential for treaty claims to hold.

The Cyprus-South Africa DTA provides zero withholding on all payment types, making it one of the more favourable agreements in Cyprus's treaty network for African market exposure.

The Cyprus-Ukraine DTA historically provided some of the lowest withholding rates for interest (2%) and royalties (5%) in Cyprus's treaty network. Verify current status given ongoing conflict.

The Cyprus-Singapore DTA enables clean structuring for businesses with both European and Asian operations. Singapore's 0% outbound dividend withholding combined with Cyprus's 0% inbound dividend treatment creates an efficient bilateral structure.