🇷🇺 Tax Treaty
Cyprus–Russia Double Tax Treaty
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.
Withholding Tax Rates at a Glance
(reduced rate)
(Cyprus side)
Full Withholding Tax Rates
| Payment Type | Treaty Rate | Conditions |
|---|---|---|
| Dividends (standard) | 10% | Standard WHT rate |
| Dividends (reduced) | 5% | companies investing ≥USD 100,000 in 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 (general exemption) |
Treaty signed: 1998. In force: 1999. Rates are treaty maxima — domestic law or EU directives may reduce them further.
Key Treaty Benefits
- ✓ Historically: 0% WHT on interest and royalties from Russia
- ✓ Historically: 5% WHT on dividends for qualifying investments
- ✓ Treaty currently suspended by Russia (verify current status before relying)
Common Cyprus–Russia Structures
- → Legacy Cyprus holding structures above Russian subsidiaries (review required)
Planning Notes
Note: Russia unilaterally suspended the Cyprus-Russia DTA in 2023. Payments from Russia to Cyprus may now be subject to Russian domestic withholding rates (15% on dividends, 20% on interest/royalties). Clients with Russia-sourced income should seek current specialist advice as the situation may change.
Dual Residency Tiebreaker
Mutual agreement procedure
Planning a Cyprus–Russia 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–Russia double tax treaty — with genuine substance and robust documentation.