Revised Double Tax treaty between Cyprus and France

A revised treaty for avoidance of double taxation between Cyprus and France was signed on 11 December 2023 replacing the previous Treaty of 1981.

The main provisions of the Treaty are as follows:

• Dividends: 0% withholding tax if the beneficial owner of the dividend is a company holding directly at least 5% of the capital of the dividend-paying company throughout the 365 days, otherwise a 10% withholding tax applies
• Interest: 0% withholding tax
• Royalties: 5% withholding tax
• Capital gains derived by a resident of a Contracting State from the alienation of shares (or comparable interests) in property companies may be taxed in the other Contracting State if, at any time during the 365 days preceding the alienation, such shares (or comparable interests) derive more than 50% of their value directly or indirectly from immovable property situated in that other State.

The revised provisions will enter into force once the ratification instruments are exchanged and its provisions will enter into effect from 1 January of the year following its entry into force.