Cyprus Withholding tax rates
Cyprus Withholding tax rates: no single figure applies. The reason is set out below, cited to the governing instrument. Last checked against the official source on 11 Aug 2026.
The withholding taxes Cyprus levies on payments to non-residents - dividends, interest and royalties. Cyprus withholds nothing on dividends and interest to non-residents in the general case (the Special Defence Contribution reaches only residents), 10% on royalties for rights used within Cyprus (5% for cinematograph films), and applies defensive withholding taxes on payments to companies in EU-blacklisted and, from 2026, low-tax jurisdictions. Administered by the Cyprus Tax Department (Ministry of Finance).
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| Current value | structured — see the API |
|---|---|
| In force from | 2026-01-01 |
| Official source | Ο περί Φορολογίας του Εισοδήματος Νόμος του 2002, 118(I)/2002 (consolidated text, CyLaw - the legal database of the Pancyprian Bar Association), art. 21: royalties, premiums, compensation or other income from sources within the Republic derived by a non-resident not carrying on business in the Republic 'υπόκειται σε φορολογία με συντελεστή δέκα σεντ κατά λίρα' (ten cent in the pound = 10%); art. 21A (inserted by 193(I)/2021, amended by 47(I)/2025): 10% on such income derived by a company resident or registered in a non-cooperative jurisdiction; art. 22: cinematograph film rentals 'υπόκειται σε φορολογία με συντελεστή πέντε σεντ κατά λίρα' (5%); art. 24(1): the payer 'οφείλει να παρακρατεί φόρο με το συντελεστή που καθορίζεται στα εν λόγω άρθρα' for transactions under arts. 21, 21A, 22, 23 and 23A. Dividend and interest charges live in the Special Defence Contribution Law 117(I)/2002, cited on the individual entries. |
| Last verified | 2026-08-11 |
| Verification | secondary — Corroborated, but the primary instrument was NOT read (usually the publishing host blocks automated access). NINE OF THE TEN CITATIONS ARE NOW STATUTORY; THE TENTH CARRIES A SUSPECTED WRONG VALUE, WHICH IS WHY THE SERIES IS NOT LABELLED PRIMARY. All the PwC citations, and the corporate-services-firm PDF of the Income Tax Law that fbscyprus.com was hosting, have been replaced by the consolidated texts of Law 118(I)/2002 and Law 117(I)/2002 on CyLaw, the legal database maintained by KINOP/CyLII for the Pancyprian Bar Association - an authoritative non-commercial consolidation, though not the Government Gazette itself; the Cyprus Tax Department's own site (mof.gov.cy) was unreachable and tax.gov.cy does not resolve. The outstanding problem is withholding_rates[8], dividends to associated companies in low-tax jurisdictions, served at 17%: the consolidated SDC Law reads five per cent, not seventeen. Art. 3(1)(δ)(i) draws an explicit two-way distinction - (αα) low-tax jurisdiction: 5%; (ββ) non-cooperative jurisdiction: 17% - with a proviso that a jurisdiction on both lists takes the 17%. The 5% is consistent with the rest of the reformed Law: art. 3(1)(α) now charges resident individuals 5% on dividends, down from 17%, following the περί Έκτακτης Εισφοράς για την Άμυνα (Τροποποιητικός) (Αρ. 4) Νόμος του 2025, so the low-tax defensive measure simply matches the ordinary domestic rate while the blacklist measure stays penal. The practitioner alerts that report 17% (EY, KPMG, BDO) all describe Law 48(I)/2025 as passed in April 2025, before the later 2025 amending laws - 220(I)/2025 and 245(I)/2025, the latter in force 1 January 2026 - that cut the dividend rate. Both the low-tax provisions of 48(I)/2025 and Law 245(I)/2025 commence on 1 January 2026, so the value being served today is the one in dispute. This needs a value decision. |
| Provenance | source fingerprint |
What this value means
THERE IS NO SINGLE WITHHOLDING TAX RATE, WHICH IS WHY value IS NULL. Cyprus's answer depends on the payment type, where a royalty right is used, and since 31 December 2022 on WHERE THE RECIPIENT COMPANY SITS: the general regime is 0% on dividends and interest and 10%/5%/0% on royalties, but payments to companies in EU-blacklisted (Annex I non-cooperative) jurisdictions attract 17% (dividends), 17% (interest) and 10% (royalties), and from 1 January 2026 dividends to associated companies in low-tax jurisdictions (corporate tax below 6.25%) attract 17%. A caller wanting a number must name the payment type and recipient jurisdiction class; read withholding_rates rather than expecting a headline figure. ALL RATES ARE DOMESTIC STATUTORY RATES, BEFORE TREATY RELIEF. A double-tax treaty can reduce the royalty rates, and whether relief applies depends on the recipient's residence and beneficial ownership. We do NOT serve treaty rates: they are bilateral, run to thousands of country pairs, and applying one is a legal determination rather than a lookup. Intra-EU, s. 21 of the Income Tax Law itself exempts royalties paid to a 25%-associated company of another Member State (EU Interest & Royalties Directive as implemented); the Parent-Subsidiary Directive is moot in the general case because Cyprus withholds nothing on outbound dividends anyway. The series effective_from is 1 January 2026, the most recent date on which any rate changed (the low-tax-jurisdiction 17% dividend WHT taking effect). The blacklist interest rate was 30% when the defensive measures took effect on 31 December 2022 and fell to 17% from 1 January 2024 with the general SDC interest-rate reduction. For low-tax jurisdictions, interest and royalties are hit by DEDUCTION DENIAL at the payer, not by withholding, so no entry is served for them.
Get it programmatically
curl https://euroref.dev/v1/cy/withholding-tax
# $0.005 per call — x402 on Base (USDC). No key, no signup.
# History: curl https://euroref.dev/v1/cy/withholding-tax/history?from=2020-01-01
# Provenance: curl https://euroref.dev/provenance/cy/withholding-taxOther Cyprus series: Policy interest rate · Value added tax (ΦΠΑ) · VAT registration threshold · National minimum wage · Public holidays · Consumer price index (annual inflation) · Corporate income tax · Personal income tax · Statutory social-insurance contributions · ECB main refinancing operations rate (fixed rate) · Late-payment interest (EU Late Payment Directive) · Statutory legal interest (δικαστικό επιτόκιο)
The same figure elsewhere: Czech Republic · Denmark · Estonia · Finland · France · all 34