🇳🇱 Tax Treaty
Cyprus–Netherlands Double Tax Treaty
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.
Withholding Tax Rates at a Glance
(reduced rate)
(Cyprus side)
Full Withholding Tax Rates
| Payment Type | Treaty Rate | Conditions |
|---|---|---|
| Dividends (standard) | 15% | Standard WHT rate |
| Dividends (reduced) | 0% | companies holding ≥25% of payer capital |
| Interest | 0% | On interest payments between the countries |
| Royalties | 0% | On royalties, licences, and IP income |
| Capital Gains (Cyprus side) | 0% | 0% in Cyprus on disposal of shares |
Treaty signed: 1981. In force: 1983. Rates are treaty maxima — domestic law or EU directives may reduce them further.
Key Treaty Benefits
- ✓ 0% withholding on royalties
- ✓ 0% withholding on interest
- ✓ 0% withholding on dividends (qualifying holdings)
- ✓ Robust framework for dual-holding structures
Common Cyprus–Netherlands Structures
- → Cyprus sub-holding above Dutch operating company
- → Dutch co-op structure combined with Cyprus holding for third-country income
Planning Notes
The Netherlands itself has a strong participation exemption system and generally does not withhold on outbound dividends. The treaty provides an additional layer of protection and certainty for Cyprus-Netherlands structures.
Dual Residency Tiebreaker
Place of effective management
Planning a Cyprus–Netherlands 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–Netherlands double tax treaty — with genuine substance and robust documentation.