Cyprus – Switzerland: Tax Treaty Enters Into Force

TThe Income and Capital Tax Treaty between Cyprus and Switzerland entered into force on 15 October 2015.

The provisions of the treaty will become effective on 1 January 2016.

The treaty was signed on 25 July 2014.

In accordance with the treaty, the following withholding taxes will apply:

Dividends:

• 0% if the beneficial owner is a company (other than a partnership) whose capital is divided, in whole or in part, into shares and which holds directly at least 10% of the capital of the company paying the dividends for an uninterrupted period of at least 1 year.
• 0% if the beneficial owner is a pension fund or other similar institution offering pension schemes in which individuals can participate for their retirement pension.
• 15% in all other cases.

Interest: 0%.

Royalties: 0%.