The new double taxation agreement between Cyprus and Lithuania

The Double Tax Treaty between Cyprus and Lithuania, signed on June, 21st, 2013, entered into force on the 1st January 2015.
The most significant provisions of the new treaty are highlighted below: 
  1. Dividend Payments: No withholding tax (0%) shall be applied on dividend payments, provided that: the recipient is a company and is the beneficial owner of the dividends, and has a minimum direct holding of 10% of the capital of the company in question. Otherwise dividend payments will be subject to a withholding tax of 5%.
  2. Interest: No withholding tax (0%) shall be applied.
  3. Royalties: 5% withholding tax shall be applied.
  4. Capital Gains from the sale of shares will be taxed in the country of residence of the alienator. Gains from the sale of shares deriving their value or the greater part of their value directly or indirectly from exploration or exploitation rights and/or property situated in the other Contracting State and used in connection with the exploration or exploitation of the natural resources situated in that other State will be taxed in that other State.