DT5354 - Double Taxation Relief Manual: Guidance by country: Cyprus: Notes

Geographical scope

»Ê¹ÚÌåÓýapp UK considers that the convention covers the whole of the Island of Cyprus.

Dual-resident companies (Article 4(4))

»Ê¹ÚÌåÓýapp corporate residence tie-breaker at Article 4(4) follows a new approach where dual residence is determined by the competent authorities of the UK and Cyprus. This paragraph is to be read in conjunction with the guidelines set out in the Protocol.

Students (Article 19)

Visiting students, or business apprentices from Cyprus are exempt from UK tax on payments from abroad for the purpose of their maintenance, education or training.

Government service pensions (Article 18)

»Ê¹ÚÌåÓýapp 2018 Convention changes the way that government service pensions are taxed, so that from 1 January 2019, UK government pensions paid to residents of Cyprus who are not Cypriot nationals, are taxable solely in the UK. »Ê¹ÚÌåÓýapp 2018 Protocol allows affected taxpayers to elect to retain benefits under the 1974 Convention for a period of up to 5 years.