articles | 09 March 2021 | ServPRO Accountants & Consultants

Cyprus – Egypt Double Tax Treaty: Key Provisions

The Agreement between the Republic of Cyprus and the Arab Republic of Egypt for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (known as the Double Tax Treaty (DTT) between Cyprus and Egypt) has entered into force on 31 July 2020, while the preceding DTT between the two States done on 18 December 1993 has been terminated.

The key provisions of the DTT include:

•    Dividend Payments: 5% withholding tax on the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 20% of the capital of the company paying the dividends throughout a 365-day period, that includes the day of the payment of the dividend; and 10% of the gross amount of the dividends in all other cases (Article 10)

•    Interest Payments: 10% withholding tax on the gross amount of the interest (Article 11)

•    Royalty Payments: 10% withholding tax on the gross amount of the royalties (Article 12)

•    Capital Gains: gains derived by a resident of a Contracting State from the alienation of shares or any other comparable interest deriving, at any time during the 365 days preceding the alienation, >50% of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State. Gains other than the aforesaid, derived by a resident of a Contracting State from the alienation of shares, comparable interests, securities or other rights representing the capital of the company which is a resident of the other Contracting State may be taxed in that other Contracting State if the alienator, at any time during the 365 days preceding such alienation, held directly or indirectly at least 20% of that company. The aforesaid provisions do not apply to gains derived from the alienation of shares listed on an approved stock exchange (Article 13).


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