Post by Salkovic on Apr 29, 2009 2:07:00 GMT 4
Cyprus: Cyprus signs double tax agreement with Qatar
The Cyprus – Qatar double taxation agreement was concluded between May 22 – 27 2007 and subsequently approved by the Council of Ministers on August 27 2008. The agreement was signed by the Cypriot minister of finance on behalf of the government on the November 11 2008, and countersigned by the minister of finance of Qatar upon ratification. Qatar ratified the treaty on January 26 2009.
This treaty is based on the OECD model convention, and accordingly incorporates the following provisions:
Taxes covered
In the case of the Republic of Cyprus the taxes covered under this agreement are:
* the income tax,
* the special contribution for the defence fund, and
* capital gains tax
Dividends, interest, royalties and capital gains
* Dividends may only be taxed in state of residence of the recipient.
* Interest may only be taxed in the state of residence of the recipient.
* Royalties may be taxed at source, at a rate not exceeding 5%.
* Capital gains deriving from the disposal of immovable property may be taxed at the level of the country in which the immovable property is situated. Equally, capital gains deriving from the alienation of movable property of a permanent establishment may be taxed at the level of the country in which the said permanent establishment is established. In addition, gains deriving from the disposal of shares, whereby more than 50% of their value is the outcome of immovable property, may be taxed at the level of the country in which the property is situated at.
Independent and dependent personal services, pensions and annuities and directors' fees
Income deriving from independent professional services may only be taxed at the person's country of residence, unless a fixed base is also available to the said person in the other contracting state or where the 183 days of residence in any 12-month period in the other contracting state is equally established.
Employment income is only taxable at the level of the state of residence of a person, unless it is exercised in the territory of the other contracting state. In any case, the country of residency of a person shall tax employment income in cases where the employee is not a resident of the other contracting state for a period of over 183 days in any 12-month period, or the payment in made directly by a person resident of the country of residence of the employee, or where no permanent establishment is deemed to exist in the other contracting state.
Pensions on past employment are only taxable by the paying contracting state.
Directors' fees may be taxed by the country of residency of the company in which an individual holds the position of a director.
Miscellaneous
The credit method is applied as the means of eliminating double taxation, whereby a tax credit is allowed at the level of the receiving state with respect to any taxes paid at the level of the source state.
The exchange of information provision is also included in this agreement.
Sead Dado Salkovic
sead.salkovic@eurofastglobal.eu
The Cyprus – Qatar double taxation agreement was concluded between May 22 – 27 2007 and subsequently approved by the Council of Ministers on August 27 2008. The agreement was signed by the Cypriot minister of finance on behalf of the government on the November 11 2008, and countersigned by the minister of finance of Qatar upon ratification. Qatar ratified the treaty on January 26 2009.
This treaty is based on the OECD model convention, and accordingly incorporates the following provisions:
Taxes covered
In the case of the Republic of Cyprus the taxes covered under this agreement are:
* the income tax,
* the special contribution for the defence fund, and
* capital gains tax
Dividends, interest, royalties and capital gains
* Dividends may only be taxed in state of residence of the recipient.
* Interest may only be taxed in the state of residence of the recipient.
* Royalties may be taxed at source, at a rate not exceeding 5%.
* Capital gains deriving from the disposal of immovable property may be taxed at the level of the country in which the immovable property is situated. Equally, capital gains deriving from the alienation of movable property of a permanent establishment may be taxed at the level of the country in which the said permanent establishment is established. In addition, gains deriving from the disposal of shares, whereby more than 50% of their value is the outcome of immovable property, may be taxed at the level of the country in which the property is situated at.
Independent and dependent personal services, pensions and annuities and directors' fees
Income deriving from independent professional services may only be taxed at the person's country of residence, unless a fixed base is also available to the said person in the other contracting state or where the 183 days of residence in any 12-month period in the other contracting state is equally established.
Employment income is only taxable at the level of the state of residence of a person, unless it is exercised in the territory of the other contracting state. In any case, the country of residency of a person shall tax employment income in cases where the employee is not a resident of the other contracting state for a period of over 183 days in any 12-month period, or the payment in made directly by a person resident of the country of residence of the employee, or where no permanent establishment is deemed to exist in the other contracting state.
Pensions on past employment are only taxable by the paying contracting state.
Directors' fees may be taxed by the country of residency of the company in which an individual holds the position of a director.
Miscellaneous
The credit method is applied as the means of eliminating double taxation, whereby a tax credit is allowed at the level of the receiving state with respect to any taxes paid at the level of the source state.
The exchange of information provision is also included in this agreement.
Sead Dado Salkovic
sead.salkovic@eurofastglobal.eu