Cyprus` double taxation treaties could be as follows Cyprus has signed in recent years a number of other double taxation mitigation treaties (see table below for a list of tax treaties signed by Cyprus). A double taxation treaty between Cyprus and Iran was ratified in January 2017. This agreement will enter into force on 1 January 2018. The agreement is based on the OECD Model Convention for the Avoidance of Double Taxation of Income and Capital. The main effects of the contract on real estate and shipping are expected to be the main ones. It will also allow Iranian businessmen to access the EU market. Cyprus and Barbados signed a double taxation convention for the first time in London on 3 May 2017. Its full title was “Agreements for the Avoidance of Double Taxation and the Prevention of Income-Based Tax Evasion between the Republic of Cyprus and Barbados”. The agreement is based on the OECD Model Convention for the Avoidance of Double Taxation. The treaty was ratified by Cyprus on 12 May and is expected to enter into force on 1 January 2018. The main amendment to the agreement concerns the taxation by the State of the source of capital gains in companies that mainly hold real estate as their main activity. If more than half of the company`s assets include Russian real estate, Russia can apply its national capital gains tax. This is in line with the articles of the OECD Model Agreement.
Prior to this amendment, capital gains tax was applied in the country of residence of the selling company. In addition, real estate funds and investment funds treat their dividends as real estate income within the meaning of the contract. The following countries are among those that have concluded double taxation treaties with Cyprus, although not all are in force at the time of the letter: BulgariaThe Bulgarian Tax Convention and international agreements Cyprus also have tax-saving provisions with 15 countries, including Canada; the Czech Republic; Denmark; Germany; Greece; India; Ireland, Italy; Malta; Romania; Slovakia; Sweden; Syria; the United Kingdom; and Yugoslavia. In addition, Cyprus has signed investment promotion and protection agreements with more than 20 other countries. These bilateral agreements contain, inter alia, guarantees against discriminatory treatment, guarantees for the repatriation of capital and profits in a freely convertible currency and rules on compensation in the event of expropriation of property. Among the countries with which Cyprus has concluded such agreements are Armenia, Belgium/Luxembourg, Bulgaria, the Czech Republic, China, Egypt, Greece, Hungary, India, Israel, Lebanon, Libya, Malta, Moldova, Poland, Romania, San Marino, Seychelles, Serbia and Montenegro and Syria. In September 2010, Panamanian President Ricardo Martinelli met with his Cypriot counterpart Demetris Christofias to discuss improving economic cooperation, including the signing of an agreement to avoid double taxation and tax evasion. Get free tax advice from our experts if you are considering using a Cypriot company in a particular structure.
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