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Cyprus - Norway Double Tax Treaty
Area(s) of Practice: Taxation Law

The Cyprus Government has signed and ratified the new Treaty for the Avoidance of Double Taxation with Norway, which came into effect on 20 June 2014.

Prior to this date, double taxation matters between Cyprus and Norway, had been regulated by the 1951 double tax agreement between Cyprus and the United Kingdom, which extended to all British colonies at that time. Since Cyprus's independence, it is the first time that an independent double tax agreement comes into force between the two countries. It is a treaty that expands Cyprus’s existing network of double tax agreements, and it is expected that economic cooperation between Cyprus and Norway will be enhanced further.

The main provisions of the new treaty include the following:

a) Where the beneficial owner is a company (other than a partnership) which holds directly at least 10% of the capital of the company paying the dividends, there will be no withholding tax on the dividend. In all other cases dividend payments may be subject to a maximum of 15% withholding tax.
b) Interest payments will not be subject to withholding tax.
c) Royalty payments will not be subject to withholding tax.
d) Gains derived by a resident of a contracting state, from the alienation of immovable property situated in the other contracting state, may be taxed in that other state.

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