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This agreement covers taxes on income, including Cyprus's capital gains tax. A Permanent Establishment is created by a construction site or project lasting more than six months (Article 5). Dividends (Article 10) and interest (Article 11) are taxable only in the recipient's state of residence. Royalties may be taxed in the source state, but withholding is capped at 5% (Article 12). Capital gains from shares deriving over 50% of their value from immovable property may be taxed in the state where the property is located (Article 13). The credit method eliminates double taxation (Article 23).

Agreement between the Government of the STATE of QATAR and the Government of the REPUBLIC of CYPRUS for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income

The Government of the Republic of Cyprus and The Government of the State of Qatar, desiring to conclude an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, have agreed as follows:

Contents

Article 1 - Persons Covered

Article 2 - Taxes Covered

Article 3 - General Definitions

Article 4 - Resident

Article 5 - Permanent Establishment

Article 6 - Income From Immovable Property

Article 7 - Business Profits

Article 8 - Shipping and Air Transport

Article 9 - Associated Enterprises

Article 10 - Dividends

Article 11 - Interest

Article 12 - Royalties

Article 13 - Capital Gains

Article 14 - Independent Personal Services

Article 15 - Dependent Personal Services

Article 16 - Directors' Fees

Article 17 - Artists and Sportspersons

Article 18 - Pensions and Annuities

Article 19 - Government Service

Article 20 - Teachers and Researchers

Article 21 - Students and Trainees

Article 22 - Other Income

Article 23 - Elimination of Double Taxation

Article 24 - Non-Discrimination

Article 25 - Mutual Agreement Procedure

Article 26 - Exchange of Information

Article 27 - Members of Diplomatic Missions and Consular Posts

Article 28 - Entry Into Force

Article 29 - Termination

Article 1
Persons Covered

This Agreement shall apply to persons who are residents of one or both of the Contracting States.

Article 2
Taxes Covered

This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied. There shall be regarded as taxes on income, all taxes imposed on total income or on elements of income. The existing taxes to which the Agreement shall apply are:

in the case of the State of Qatar:
1. taxes on income
(hereinafter referred to as 'Qatari tax'); and
in the case of the Republic of Cyprus:
1. the income tax;
2. the corporate income tax;
3. the special contribution for the defence of the Republic; and
4. the capital gains tax;
(hereinafter referred to as 'Cyprus tax').

Article 1Persons Covered

Article 2Taxes Covered

Article 1
Persons Covered

Article 2
Taxes Covered