On 18 May 2018, Cyprus and Andorra signed a double tax agreement which is based on the OECD Model Convention. The treaty was published in the Official Gazette of the Republic on 1 June 2018.
The key provisions of the agreement are summarised below:
- No withholding tax on dividend payments
- No withholding tax on interest payment
- No withholding tax on royalty payments
- With regards to capital gains, the treaty mentions that gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 % of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State. However, this shall not apply to gains derived from the alienation of shares of a company listed on a recognised stock exchange of one or both Contracting States or a European Union or European Economic Area Member State, where the alienator at all times during the 12-month period preceding such alienation held directly or indirectly not more than 25% of the capital of the company whose shares are alienated.
- Exchange of exchange of financial and other information as per the provisions of article 25 the treaty
The treaty will enter into force once both Cyprus and the Andorra exchange notifications that their formal ratification procedures have been completed.