The Double Tax Treaty that was signed between Cyprus and Switzerland on 25 July 2014 entered info force on October 15 and has now been ratified by Switzerland and will come into effect as from 1st January 2016.
Below are the provisions of the treaty in accordance to the agreement:
Dividends
Dividend payments by Switzerland will be: subject to a withholding tax (WHT) of 15%, which may be reduced to 0% if the beneficial owner (other than a partnership) holds directly at least 10% of the capital of the dividend paying company for an uninterrupted period of at least 1 year.
Interest
Interest payments from Switzerland to Cyprus will be exempt from any WHT in Switzerland.
Capital Gains
Gains derived by a Cyprus company from the alienation of shares of a Swiss company deriving more than 50% of their value directly or indirectly from immovable property situated in Switzerland may be taxed in Switzerland.
In all other cases, capital gains derived by a Cyprus company from the sale of shares of a Swiss company will be subject to taxation only in Cyprus. Please note that the Treaty does not contain a limitation of benefits clause.
More information:
Do you want to establish a company in Cyprus? Our
Cyprus company formation page explains it all.
Interested in opening a bank account in Cyprus? Check our
Eurobank Cyprus bank account opening.