On 1 June 2021, the Kingdom of Netherlands and Cyprus signed the
double tax treaty for the avoidance of double taxation (the
"treaty"), which was published in the Official Gazette on
4 June 2021, the date of ratification by Cyprus.
The Treaty follows the model treaty of the Organisation for
Economic Co-operation and Development (OECD) containing the
standard provisions, to avoid double taxation of income and
capital, which are briefly outlined below:
Dividends:
The withholding tax on dividends paid to the other contracting
state is 15%, except in the following two instances for which no
withholding tax (WHT) is imposed if:
- the beneficial owner (BO) is a company that holds directly at
least 5% of the capital of the company paying the dividends,
throughout a 365-day period that includes the day of the dividend
payment;
