Currency control
There are no currency controls.
Capital gains tax
Charged at the rate of 20%. Taxable on gains from the disposal of immovable property situated in Cyprus, including gains from the sale of shares in companies directly owning such immovable property.
Taxes at source
Dividends, interest and royalties paid to non-residents of Cyprus are not subject to withholding tax in Cyprus unless the royalties are paid in respect of intellectual property rights used in Cyprus, in which case the royalties are subject to a withholding tax rate of 10% (5% for cinematographic films). This tax may be reduced to zero under double tax treaties (SITT) or under an EU Directive.
Withholding tax on other types of income:
At the rate of 10%, remuneration of non-residents of Cyprus for services of a technical nature originating from sources in Cyprus is taxed. Exceptions: if such services were rendered through a permanent establishment of a non-resident company in Cyprus, or if such services were rendered between related companies falling within the relevant definition of the EU Directive.
At a rate of 10% is withheld on gross income and receipts derived by non-resident individuals from the exercise of their profession in Cyprus, as well as remuneration of non-resident public entertainers (such as theatrical, musical, including soccer clubs, other sporting assignments, etc.).
At the rate of 5% is withheld on gross income derived in Cyprus by non-residents of Cyprus in respect of the extraction, exploration or utilization of the continental shelf, as well as the construction and utilization of pipelines and other structures on land, on the seabed or on the sea surface.
CFC Rules
As of January 1, 2019, the Controlled Foreign Company (CFC) rules apply, i.e. undistributed profits of a CFC directly or indirectly controlled by a Cyprus tax resident company may be taxed in Cyprus (subject to certain exceptions).
Non-Cyprus resident companies are subject to tax on profits accrued or derived from the business activities of a permanent establishment in Cyprus, as well as on certain types of income derived from sources in Cyprus. Taxes paid abroad may be deducted from the Cyprus income tax payable.