In Cyprus, a Special contribution for defence is imposed on certain types of income.
Non-residents are exempt from this contribution.
Dividends received by a Cyprus tax resident company from a non-resident company will be subject to special contribution for defence if the non-resident company paying the dividend engages directly or indirectly more than 50% in activities leading to investment income and the foreign tax burden on the income of the dividend-paying company is substantially lower than the tax burden of the Cyprus tax resident company.
Dividends received from a resident or non-resident companies are subject to special defence contribution at 17% (15% up to 30 August 2011, 17% from 31 August 2011 to 31 December 2011, 20% for 2012 and 2013) but only on resident persons. Non-resident persons are not liable to special defence contribution.
Deemed dividend distribution
If a Cyprus tax resident company does not distribute by way of a dividend at least 70% of its accounting profits within two years from the end of the tax year then the company is deemed to have distributed such profits and is liable to pay 17% (15% up to 30 August 2011, 17% from 31 August 2011 to 31 December 2011, 20% for 2012 and 2013) special contribution for defence on the deemed dividend distribution applicable to its shareholders who are Cyprus tax residents.
A non-Cyprus tax resident receiving dividends from profits subject to a deemed distribution is eligible to a tax refund.
Interest income which is not closely connected with its business, earned by a Cyprus tax resident company, is subject to 10% contribution up to 30 August 2011, 15% up to 28 March 2013 and 30% thereafter.
Tax credit for foreign tax paid
Any tax suffered abroad on income that is subject to defence contribution will be credited against any defence contribution payable on such income irrespective of the existence of a double taxation treaty.