- Statutory Instrument 32 of 2006
- Primary work
- Business Tax Act, 2009
- 8 November 2017
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Business Tax Act, 2009
Business Tax (Double Taxation Agreement) (No. 2) Regulations, 2006
Statutory Instrument 32 of 2006
- Commenced on 2 November 2006
- [This is the version of this document at 8 November 2017.]
1. CitationThese Regulations may be cited as the Business Tax (Double Taxation Agreement) (No. 2) Regulations, 2006.
2. Declaration and effect of AgreementIt hereby declared that the Government of the Republic of Cyprus and the Government of the Republic of Seychelles have entered into the agreement specified in the Schedule for the purposes of avoidance of double taxation and prevention of fiscal evasion and that the agreement shall have effect in relation to the tax imposed under this Act.
Agreement between the Government of the Republic of Cyprus and the Government of the Republic of Seychelles for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capitalThe Government of the Republic of Cyprus and the Government of the Republic of Seychelles,Desiring to conclude an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital,Have agreed as follows:
Article 1 – Persons coveredThis Agreement shall apply to persons who are residents of one or both of the Contracting States.
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 – Income from employment
Article 15 – Directors‘ feesDirectors‘ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other State.
Article 16 – Entertainers and sports persons
Article 17 – Pensions
Article 18 – Government service
Article 19 – Students and apprenticesPayments which a student or business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.
Article 20 – Other income
Article 21 – Capital
Article 22 – Elimination of double taxation
Article 23 – Non-discrimination
Article 24 – Mutual agreement procedure
Article 25 – Exchange of information
Article 26 – Members of diplomatic missions and consular postsNothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular posts under the general rules of international law or under the provisions of special agreements.
Article 27 – Entry into force
Article 28 – Termination
|H.E. Michael SardsMinister of FinanceFor the Government of the Republic of Cyprus||Mr. Jacquelin DugasseMinister of Economic Planning and EmploymentFor the Government of the Republic of Seychelles|
ProtocolArticle 5 paragraph 6It is understood that the provisions of this paragraph shall take effect from the first day of January next following the year in which communication is received by the Government of Seychelles from the Government of Cyprus in respect of the appropriate provision having been incorporated into the domestic legislation of Cyprus.
History of this document
02 November 2006