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Cyprus-Iran Double Taxation Treaty

September 17, 2015

On the 4th of August, 2015 Cyprus and Iran signed a Double Tax Treaty agreement during an official visit of the Iranian Finance Minister in Cyprus is hoped to strengthen and develop the economic relations and allow for the expansion of investment and business opportunities between Iran and Cyprus.

This agreement was decided three weeks after world powers reached a deal on Iran`s nuclear activity to begin removing global sanctions between Iran and Europe.

The new agreement opens up new business prospects for the expansion and progression of the Cyprus network of Double Taxation Agreements, which is of high political and economic importance and aims to further strengthen and attract foreign investment between Iran and Cyprus.

Important changes:

  • Dividends: 5% withholding tax on dividends paid, if the Beneficial Owner of the dividends is a company holding at least 25% of the capital of the company paying the dividend, in all other cases 10%.
  • Interest: 5% withholding tax.
  • Royalties: 6% withholding tax.
  • Capital Gains: Gains received from the sale or disposal of immovable property may be taxed in the country where the property is located. Gains from the sale or disposal of shares, totalling more than 50% of their value directly or indirectly from immovable property may be taxed in the country where the property is situated.

Permanent Establishment: The permanent establishment definition included in the treaty complies with the requirements as stated in the OECD Model Tax Convention. Specifically, a building site, construction project, assembly or installation venture, supervisory activities or similar, constitutes permanent establishment providing it lasts for a total of 12 months or longer.

The DTT is based on the OECD Model and is expected to enter into force on the 1st of January 2016, following the official date of the approval by both countries.

Why incorporate in Cyprus?

Cyprus has been a member of the European Union since 2004, and a member of the Eurozone since 2008 and already assumed on successful term of the EU presidency throughout 2012. The geographic location of Cyprus, connecting Europe to Africa, the Middle East and Asia naturally make the island a hub for business and trading.

In the last few decades, Cyprus has established itself as a reputable and trustworthy financial centre complemented by an advanced legal, accounting and banking system, highly skilled and multi-lingual workforce, excellent telecommunication systems and convenient year round flight and connections.

The tax legislation in Cyprus is fully compliant with the EU Directives and in full compliance with the code of conduct for business taxation and against harmful tax competition. As of April 2009, Cyprus is featured on the OECD white list. The Cyprus tax legislation is fully compliant with the EU Directives and in full compliance with the other factors which we will state.

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