The Convention between the Republic of Cyprus and the Hashemite Kingdom of Jordan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (known as the Double Tax Treaty (DTT) between Cyprus and Jordan) was signed on 17 December 2021 and published in the Official Gazette of the Republic of Cyprus on 31 December 2021.
The Cyprus – Jordan DTT is based on the OECD Model Tax Convention and its key provisions include:
- Dividend Payments: 5% withholding tax if the beneficial owner is a company (other than a partnership), which holds directly at least 10% of the capital of the company paying the dividends. In all other cases, a maximum rate of 10% withholding tax applies (Article 10)
- Interest Payments: 5% withholding tax on the gross amount of the interest where beneficial owner of the interest is a resident of the other Contracting State. No withholding tax for interest payments where the beneficial owner of the interest is the Government, a political subdivision, a local authority, or the National Bank of the other Contracting State (Article 11)
- Royalties & Fees for Technical Services: 7% withholding tax on the gross amount of the royalties or fees for technical services where the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State (Article 12)
- Capital Gains: gains derived by a resident of a Contracting State from the alienation of shares in a company deriving >50% of their value directly from immovable property situated in the other Contracting State may be taxed in the latter (this provision applies only to those gains attributable to the immovable property). The aforesaid provision does not apply to gains derived from the alienation of shares listed on an approved stock exchange (Article 13)
- Entitlement to Benefits: the DTT includes provisions that limit the entitlement to benefits arising thereunder. In particular, the competent Tax Authority of each respective State is entitled to deny a benefit where the obtainment of such benefit was one of the principal purposes of the arrangement or transaction at issue, unless the granting of that benefit would be in accordance with the objectives of the DTT (Article 29)
Cyprus – Germany Double Tax Treaty (DTT) Amending Protocol
The Amending Protocol to the Convention between the Republic of Cyprus and the Federal Republic of Germany for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital (known as the Double Tax Treaty (DTT) between Cyprus and Germany), which was signed on 19 February 2021 and published in the Official Gazette of the Republic of Cyprus on 5 March 2021, has entered into force on 8 December 2021.
Cyprus – Switzerland Double Tax Treaty (DTT) Amending Protocol
The Amending Protocol to the Convention between the Republic of Cyprus and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital (known as the Double Tax Treaty (DTT) between Cyprus and Switzerland), which was signed on 20 July 2020 and published in the Official Gazette of the Republic of Cyprus on 24 July 2020, has entered into force on 3 November 2021.
