Cross-Border Tax
Cyprus has 65+ active double-tax treaties. We walk through six worked examples showing how the treaty applies in practice: UK (post-Brexit), US (1985 treaty + LOB), India (revised 2016), Israel (2017 protocol), UAE (0% on most flows), Singapore (5% qualifying dividend).11 min read · By Nexora Cyprus editorial team · Reviewed by an ICPAC-registered Cyprus tax adviser engaged by Nexora
The DTA framework
Cyprus's DTA network has been a key competitive advantage since the 1970s: 65+ active treaties, mostly OECD-MTC-aligned, mostly post-MLI (Multilateral Instrument) updated. Cyprus does not levy outbound WHT on dividends (0% domestic to any country), so DTAs are typically used for SOURCE-state WHT reductions on inbound flows.
Post-Brexit, the Cyprus-UK DTT remains the primary tax framework between the two countries. Key headline rates (assuming substance + PPT compliance):
The Cyprus-US DTA dates from 1985 and includes a Limitation on Benefits (LOB) clause designed to prevent third-country residents from accessing the treaty by routing through Cyprus. Practical headline rates:
The 2016 India-Cyprus protocol restored Cyprus to favourable treaty status (after a 2013 'non-cooperative' designation). Now widely used for India-inbound investments via Cyprus holding companies.
The BEPS MLI (signed 7 June 2017, in force in Cyprus from 1 May 2020) overlays a Principal Purpose Test (PPT) on nearly all of Cyprus's DTAs. Under PPT, treaty benefits are denied if 'obtaining the benefit was one of the principal purposes' of any arrangement. Substance + commercial purpose documentation is the defence.
Several treaties also have explicit LOB clauses (most notably US, Singapore) layered on top of PPT.
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Disclaimer: This article is for informational purposes only and does not constitute legal, tax, or financial advice. Tax laws change frequently. Consult a qualified Cyprus adviser for guidance specific to your situation. The information on this page is general guidance only and does not constitute legal, tax, accounting, immigration or financial advice. Specific advice should be obtained based on the facts of each case.
— Authoritative sources cited
All statutory references and quoted figures in this article are sourced from the above primary publications. Cited as of 2026-05-01T00:00:00+03:00. Reviewed by an ICPAC-registered Cyprus tax adviser engaged by Nexora.
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