• Cyprus - Russia
    Amending protocol enters into force


    The amending protocol to the Cyprus - Russia Income and Capital tax Treaty has entered into force on 2 April 2012. The provisions of the amending protocol will be effective from 1 January 2013 (except for capital gains provisions which will take effect from 1 January 2017).

    Under the amending protocol, withholding tax rates for dividends, interest and royalties remain the same. However, for the application of the reduced withholding tax rate on dividends, the investment threshold will be €100,000 (instead of US$100,000).

    In addition, under the amending protocol, capital gains from the disposal of shares will remain under the exclusive taxing right of the country of residence of the seller. However, where the disposal of shares is of a company which derives a substantial part of its value (more than 50%) from immovable property situated in the other country then the taxing right is shifted to the other country. This change will come into effect as of 1 January 2017. Back to News

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