Cyprus: Income tax treaty with Switzerland | KPMG | GLOBAL

Cyprus: Income tax treaty with Switzerland, effective 2016

Cyprus: Income tax treaty with Switzerland

An income tax treaty between Cyprus and Switzerland has entered into force, and will be effective 1 January 2016.


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The Cyprus-Switzerland income tax treaty does not include a limitation on benefits (LOB) clause. 

Withholding tax provisions

The treaty includes the following withholding tax provisions:

  • Dividend payments subject to a 15% withholding tax, or 0% if the beneficial owner (not a partnership) holds directly 10% of the capital of the company paying the dividend for an uninterrupted one-year period
  • Interest payments are exempt from withholding tax
  • Royalty payments are exempt from withholding tax

The treaty also includes rules for the tax treatment of capital gains. 


Read a 2015 report [PDF 314 KB] prepared by the KPMG member firm in Cyprus: Cyprus – Switzerland Double Tax Treaty enters into force

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