Cyprus and Barbados have concluded and signed a Double Taxation Avoidance Agreement (DTTA) on 3 May 2017 in London. The DTTA generally complies with the provisions of the OECD Model Convention and will come into force as from the 1st January next following the year in which each country completes the ratifications process.
The treaty sign off was well received by the business communities of the two countries and it further enhances Cyprus position as an international business center, since some of its provisions are deemed to be significantly favorable. The DTTA’s main provisions are analyzed below:
Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 6 months (definition in compliance with OECD model).
The withholding tax rate on dividends is set at 0%.
The withholding tax rate on interest is set at 0%.
The withholding tax rate on royalties is set at 0%.
Gains from the disposal of immovable property are taxed in the country where the immovable property is situated. Capital gains arising from the disposal of shares deriving more than 50% of their value directly or indirectly from immovable property in the other Contracting State may be taxed in that other State. Other capital gains from the alienation of any other property are taxable only in the place of residence of the alienator.