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Cyprus Introduces New Defensive Measures on Dividend, Interest, and Royalty Payments to Non-Cooperative and Low-Tax Jurisdictions

01 May 2025

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Approved Changes

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Cyprus

Cyprus published Law No. 47(I)/2025 and Law No. 48(I)/2025 in the Official Gazette on 16 April 2025, introducing new and revised defensive measures on outbound payments of dividends, interest, and royalties to non-cooperative and low-tax jurisdictions where the paying company and receiving company are associated/related (50% direct or indirect ownership). The measures also apply for payments to permanent establishments of non-Cyprus companies in non-cooperative and low-tax jurisdictions, with certain exceptions. For the purpose of the measures, a jurisdiction is considered non-cooperative if listed in the EU list of non-cooperative jurisdictions at the time of the transaction (current year) and in...