New Double Tax Treaty between Cyprus & Jersey

On 11th July 2016, a Treaty for the Avoidance of Double Taxation on Income (‘DTT’) was signed between the Republic of Cyprus and the Government of the Republic of Jersey in London. The DTT is based on the OECD Model.  This is due to come into force on 1 January 2017, provided both countries have concluded their individual ratification procedures by the end of 2016.


The most significant provisions of the new treaty are highlighted below:


Dividends: Withholding tax rate: 0%

Interest: Withholding tax rate: 0%

Royalties: Withholding tax rate: 0 %

Capital Gains: Gains from the disposal of immovable property are taxed in the country where the immovable property is situated. For movable property connected with a permanent establishment, gains will be taxed in the location of the permanent establishment.  Gains from the disposal of shares are taxable in the country of which the seller is located, irrespective if the value is derived directly or indirectly from immovable property.