🇮🇪 Tax Treaty
Cyprus–Ireland Double Tax Treaty
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.
Withholding Tax Rates at a Glance
(standard rate)
(Cyprus side)
Full Withholding Tax Rates
| Payment Type | Treaty Rate | Conditions |
|---|---|---|
| Dividends (standard) | 0% | Standard WHT rate |
| Interest | 0% | On interest payments between the countries |
| Royalties | 0% | On royalties, licences, and IP income |
| Capital Gains (Cyprus side) | 0% | 0% in Cyprus; Ireland may tax Irish-source gains |
Treaty signed: 1968. In force: 1970. Rates are treaty maxima — domestic law or EU directives may reduce them further.
Key Treaty Benefits
- ✓ 0% withholding on dividends, interest, and royalties
- ✓ Full treaty protection for Irish-Cyprus business flows
Common Cyprus–Ireland Structures
- → Cyprus and Ireland dual-structure for US market access (rare but used for specific US tax structures)
Planning Notes
One of the oldest Cyprus treaties. Ireland itself has a 12.5% corporate rate; the Cyprus-Ireland combination is rarely used for rate arbitrage, but is relevant for substance-based structures combining both locations.
Dual Residency Tiebreaker
Place of effective management
Planning a Cyprus–Ireland structure?
Treaty rates are only part of the picture. We help you design and implement Cyprus company structures that take full advantage of the Cyprus–Ireland double tax treaty — with genuine substance and robust documentation.