articles | 30 November 2016 | ServPRO

Cyprus and India Double Tax Treaty revised

On the 18 November 2016, Cyprus and India signed a revised double tax agreement to replace the one which was signed between the two countries in 1994.

The new agreement was published in the Official Gazette of the Republic of Cyprus on the 25 November and will come into force after both countries have notified each other that the ratification process in each country has been completed. 

The provisions of the treaty will be effective in Cyprus on or after 1 January following the date the Agreement enters into force and in India on or after 1 April of the fiscal year following the date it enters into force.

The key amendments of the agreement are summarised below:

The definition of permanent establishment has been widened and it now includes a building site or construction, installation or assembly project or supervisory activities in connection with such a site if it lasts more than 6 months as opposed to the previous 12 months.
10% withholding tax shall be imposed on dividends. 
10% withholding tax shall be imposed on interest payments and 0% if the beneficial owner of the interest is the government, a political sub-division, a local authority of the other contracting state as well as certain Indian institutions defined in the treaty or any other institution as may be agreed upon between the competent authorities of the contracting states.
10% withholding tax shall be imposed on royalties as opposed to the previous 15%.
exchange of information between the competent authorities. 

Note that under the Cyprus and Indian tax legislation there is no withholding tax on dividend payments in and out of the countries to non-residents. Furthermore, Cyprus does not impose any withholding taxes on interest and royalties paid to non-residents.

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