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Dividends

· A resident company, which receives dividend from another Cyprus resident company, is relieved from the payment of any defence contribution.

· A company (resident or non resident) with a permanent establishment in Cyprus receiving dividend from a non-resident company is relieved from contribution to the defence fund if:

- It holds at least 1% of the share capital of the company paying the dividend; and

- If the activities of the non-resident company lead to less than 50% investment income and the income tax charged on these profits is not substantially less than the corresponding Cyprus Income Tax.

Deemed distribution

· A company resident in Cyprus for tax purposes shall be deemed to have distributed 70% of its accounting profits (after deduction of tax paid on these profits and transfers to legal reserves) in any fiscal year by way of a dividend to its resident shareholders at the end of the second year following the end of the said financial year, in which the profits were made. The company shall be obliged to effect payment to the Inland Revenue equal to 15% of the amount of the deemed dividend distribution. Such dividend shall be reduced by the amount of dividends actually distributed. Deemed distributions are not applicable to non-resident shareholders.

Other

· A resident company receiving interest income is subject to a tax rate of 10% (at source).

· A resident company receiving rent income is subject to a tax rate of 3% on the rental income after the deduction of 25% for allowable expenses.

· Upon the reduction of the share capital of a company, any undistributed reserves will be considered as deemed distributions.

· IBC’s which have opted to be taxed at Income Tax rates of 4,25% for the years 2003, 2004 and 2005, will be relieved from the contribution to the defence fund on any income which might have otherwise been taxable.

· The above provisions are not applicable to ship owning and ship management companies

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