Article 9(B) of the Income Tax Law 2002 (as amended) provides
for a notional interest deduction for tax purposes on new equity
capital (paid-up share capital and share premium) injected into
companies and permanent establishments of foreign companies on or
after 1 January 1 2015 to finance business assets, calculated by
applying a reference rate to the new equity.
The reference rate is the higher of the 10-year government bond
yield of Cyprus or the country in which the assets funded by the
new equity are used, in each case plus three percentage points. The
bond yield rates to be used are as of December 31 of the year
preceding the year of assessment.
The Tax Department has now announced the 10-year government bond
yields as of 31 December 2018, which will be used as the basis for
the notional interest deduction for the 2019 tax year, for the
following countries.