DOUBLE TAXATION AGREEMENTS

NOTES

1. If interest is less than €200,000 dividends are subject to 10% withholding tax provided that the recipient company holds directly 25% of the share capital of the paying company. In all other cases 15% is withheld.

2. 10% on the gross if the recipient is a company with not less than 25% direct share holding. In all other cases 15% is withheld.

3. Subject to certain exemptions.

4. Nil if interest is paid by the government of the other state or statutory body to the central bank of the other state. These rates shall not apply in case Bulgarian residents hold at least 25% of the share capital of the Cypriot resident paying the interest, except where Cypriot resident is not liable to tax which is lower than the usual tax rate.

5. Rate applies if shares of at least 10% share capital are held for an uninterrupted period of one year. In all other cases 5% is imposed on dividend gross amount.

6. At the rate applicable according to the domestic legislation.

7. 10% if received by a company with at least 10% direct share interest. In all other cases 15% is withheld.

8. 10% if received by a company with at least 25% direct share interest; 27% if recipient is a company with more than 25% direct or indirect share interest as long as the German corporate tax on distributed profits is lower than that on undistributed profits and the difference between the two rates is 15% or more; 15% in all other cases is withheld.

9. 5% on films and TV royalties.

• 5% on cinematography films not including television films.

• 5% if recipient is a company with at least 25% direct share interest. In all other cases 15% is withheld.

• Nil if royalties are on literary, artistic or scientific work including films, cinematography films or tapes for radio broadcasting or television.

• 5% in case the beneficial owner holds directly at least 25% of the share capital of the company paying dividends; 10% in all other cases.

• 5% if received by a company controlling less than 50% of the voting power.

• 5% on dividends paid by a company in which the beneficial owner has invested directly in the capital more than US $100,000. In all other cases, 10% is withheld.

• When received by a bank or financial institutions 7% withheld. In all other cases 10% withheld. Governmental interest payments to the other state are exempt from taxation.

• Nil when the company holds at least 25% of the share capital of the company paying the dividends. In all other cases, 15% is withheld.

• 15% for any patent, trade mark, design or model, plan, secret formula or process or any industrial, commercial or scientific equipment or for information concerning industrial, commercial or scientific experience.

• In case interest is paid to the government of the other state it is exempt from taxation. 10% imposed on the gross amount if it is received by any financial institutions, 15% withheld in all other cases.

• 10% of the gross amount of royalties received as consideration for the use of, or the right to use industrial, commercial or scientific experience, 15% of the gross amount of royalties received as consideration for the use of, or the right to use any patent, trade mark, design or model, plan, secret formula or process.

• Special tax credit provisions in place.

• 5% imposed if the recipient is a company with at least 10% direct share interest. In all other cases 15% is withheld.

• Royalties withheld should not exceed 5% withholding tax.

• Nil if interest is paid or it is guaranteed by the government of the other state or a statutory body thereof or to the central bank of the other state.

• As long as Cyprus does not impose dividend tax over and above the corporation tax, dividend payments from Cyprus to this jurisdiction shall be exempt from any tax in Cyprus chargeable on dividends.

• Nil if royalties are dramatic, musical, literary or artistic work not including film or videotape royalties.

• USSR Treaty with Cyprus is applied with: Armenia, Kyrgyzstan, Tajikistan, Uzbekistan and Ukraine. Azerbaijan, Georgia and Kazakhstan renounced it.

• Yugoslavian Treaty with Cyprus is applied with: Slovenia, Serbia and Montenegro.

Treaties not yet in force:

• Cyprus and Italy signed an amending protocol to the income tax treaty of 1974 pending ratification.
• Amending protocol to the Treaty between Cyprus and Russia has been signed on 7th October 2010 and is currently pending ratification.
• A new Treaty has been signed with Kuwait and is currently pending ratification.
• A new Treaty with Denmark has been signed on 11th October 2010 and it expects ratification.
• Slovenia and Cyprus have signed a new Treaty on 12th October 2010 and it awaits ratification.
• Cyprus and the United Arabic Emirates have concluded a new Treaty text on 19th-21st October 2010. The treaty still awaits signatures from both sides in order to proceed with ratification.