2021 Cyprus-Netherlands Income Tax Treaty Available

<p>Tax Analysts has obtained the English text of the Cyprus-Netherlands income tax treaty signed June 1 in Nicosia.</p> <p>Under the treaty, dividends are taxable at a maximum rate of 15 percent. Exemptions apply if the beneficial owner of the dividends is:</p> <ul> <li>a resident of the other contracting state and directly holds at least 5 percent of the capital of the payer company during a 365-day period that includes the date of payment of the dividends; or</li> <li>a recognized pension fund of the other contracting state that is generally exempt under the company tax or the corporate income tax laws of that other state. </li> </ul> <p>Interest and royalties are taxable only in the beneficial owner's state of residence. Cyprus generally uses the credit method to eliminate double taxation, while the Netherlands uses a combination of the credit and exemption methods.</p> <p>This is the first income tax treaty between the two countries. It will enter into force on the last day of the month following the month in which ratification instruments are exchanged, and its provisions will generally apply from January 1 of the year following entry into force. Paragraph 5 of article 23 (mutual agreement procedure) and paragraph 3 of article 24 (exchange of information) will apply only once Cyprus has notified the Netherlands through diplomatic channels of the date on which it has introduced the necessary legal basis in relation to these provisions.</p>

<p><a href="/lr/resolve//76kv3">Dutch text</a>; <a href="/lr/resolve//76kv3">Greek text</a>. <a href="/lr/resolve//76k32">Prior coverage</a>.</p>

<p>Paragraph 5 of article 23 (mutual agreement procedure) and paragraph 3 of article 24 (exchange of information) will apply only once Cyprus has notified the Netherlands through diplomatic channels of the date on which it has introduced the necessary legal basis in relation to these provisions.</p>

<p>Tax Analysts has obtained the English text of the Cyprus-Netherlands income tax treaty signed June 1 in Nicosia.</p>

Tax Analysts has obtained the English text of the Cyprus-Netherlands income tax treaty signed June 1 in Nicosia. Under the treaty, dividends are taxable at a maximum rate of 15 percent. Exemptions apply if the beneficial owner of the dividends is: a resident of the other contracting state and directly holds at least 5 percent of the capital of the payer company during a 365-day period that includes the date of payment of the dividends; or a recognized pension fund of the other contracting state that is generally exempt under the company tax or the corporate income tax laws of that other state.  Interest and royalties are taxable only in the beneficial owner's state of residence. Cyprus generally uses the credit method to eliminate double taxation, while the Netherlands uses a combination of the credit and exemption methods. This is the first income tax treaty between the two countries. It will enter into force on the last day of the month following the month in which ratification instruments are exchanged, and its provisions will generally apply from January 1 of the year following entry into force. Paragraph 5 of article 23 (mutual agreement procedure) and paragraph 3 of article 24 (exchange of information) will apply only once Cyprus has notified the Netherlands through diplomatic channels of the date on which it has introduced the necessary legal basis in relation to these provisions.

<h4>Rate Table Instructions</h4> <ul> <li>You must enter a rate for each rate type</li> <li>Enter only one rate value per row</li> <li>You may leave the country columns blank if the rate is the same for both countries</li> <li>Country names (if entered) must exactly match the jurisdictions</li> <li>Leave the Partner Country column blank if you want the rate to apply to all partners of the Main Country</li> <li>Enter "n/a" in each rate row to hide the partner in the Main Country table</li> <li>Note that the same rates may apply for Main Country and Partner Country or the Main Country may apply different rates to the Partner Country</li> </ul> <table> <tbody> <tr> <th> <div>Rate Type</div> (Dividends, Interest, Royalties)</th> <th>Main Country</th> <th>Partner Country</th> <th>Rate</th> <th>Footnote 1</th> <th>Footnote 2</th> <th>Footnote 3</th> <th>Footnote 4</th> </tr> <tr> <td>Dividends</td> <td> </td> <td> </td> <td>0/15</td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Interest</td> <td> </td> <td> </td> <td>0</td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> <tr> <td>Royalties</td> <td> </td> <td> </td> <td>0</td> <td> </td> <td> </td> <td> </td> <td> </td> </tr> </tbody> </table>

Cyprus - Netherlands: 2021 Income Tax Convention and Final Protocol

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2021 Cyprus-Netherlands Income Tax Treaty Available