Introduction
On March 22 2018 Cyprus and the United Kingdom signed a new
double tax agreement. Once it has been ratified by both parties, it
will replace the current agreement, which dates back to 1974. The
wording of the new agreement closely follows that of the 2014
Organisation for Economic Cooperation and Development (OECD) Model
Tax Convention for the Avoidance of Double Taxation on Income and
on Capital. In terms of their effect, most of the new
agreement's main provisions are substantially the same as those
in the 1974 agreement. However, the new agreement introduces modern
standards on the exchange of tax information and base erosion and
profit shifting.
Dividends
The article on dividends has been considerably shortened and
simplified to align with the OECD model tax convention. If the
beneficial owner of dividends paid by a company which is a resident
of one country is a resident of the other, the dividends are exempt
from withholding tax, unless they