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The new double taxation agreement between Cyprus and Guernsey

Cyprus has recently signed double tax treay (DTTs) with Guernsey. The DTT was published in the Gazette on 14 August 2014.
The treaty based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital.
The most significant provisions of the new treaty are highlighted below:
Cyprus – Guernsey Double Tax Treaty
Permanent Establishment: A building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve months.
Dividends: 0% withholding tax
Interest: 0% withholding tax
Royalties: 0% withholding tax
Capital gains: Gains derived by a resident of a Contracting State from the disposal of immovable property situated in the other Contracting State may be taxed in that other State.
Capital gains arising from the disposal of shares (irrespective of the underlying assets of the company of which the shares are being disposed) are taxable only in the Contracting State in which the alienator is tax resident.