The principal purpose of Double Tax Treaties is to avoid double taxation, whereby the same profits are taxed in two or more states in respect of the same person or company. Double Tax Treaties also clarify the purpose of the taxing rights of each contracting state, allowing international business to be transacted with certainty and stability. This why Double Tax Treaties are important tools for international tax planning, and certainty constitute a substantive advantage for any Country which has entered in to such Treaty. Additionally, Double Tax Treaties encourage business and investments from one country to another.
Double Tax Treaties are relevant for both income tax and corporation tax. They allow the tax payable in one country as a credit against tax payable in the contracting state with respect to the same income. Also the Treaties exempt certain classes of income from tax in one or other income state. As a rule, the Treaties contain exemptions which provide that the company in one country will not be liable to tax on commercial , business or industrial profits made in the other country unless it has a permanent establishment in that other country. The majority of Treaties determine the country where the taxpayer resides as the appropriate territory where his total income should be assessed with relief given for certain types of income which are more appropriately taxed in the country where they arise.
Among other benefits, most double tax treaties concluded by Cyprus entail:
- Elimination of double taxation in the Contracting State by way of a tax credit;
- Reduced withholding taxes or dividends, interests and royalties;
- Tax sparing provisions in the Contracting State for tax not imposed in Cyprus because of Cyprus tax incentives.