Double Tax Treaties

Cyprus has concluded a number of tax treaties with other countries. These agreements apply to offshore entities in the same way as they apply to other business entities except that certain agreements exclude offshore entities from the provisions of certain articles.

THE EXCLUSIONS ARE SUMMARISED BELOW:

• CANADA: Article 29 provides that the convention does not apply to offshore entities.
• FEDERAL REPUBLIC OF GERMANY: the protocol to the treaty reduces the full tax exemption in Germany of certain items of income and capital in the case of offshore entities, to a simple tax credit. The items of income affected are profits and capital gains of a Cyprus offshore branch as well as dividends and capital gains on immovable property and shares in the case of a Cyprus offshore company.