The double taxation agreement between Cyprus and Portugal, which was signed on 19 November 2012, has entered into force following the completion of ratification procedures by the two countries and the exchange of notifications of ratification.
The new agreement will, in general, apply as from 1 January 2014.
The latest OECD Model agreement provides for a maximum withholding tax rate of 10% on dividends, interest and royalties.
Cyprus does not impose withholding taxes except on royalties arising from use of an intellectual property asset within Cyprus, and that withholding taxes may also be eliminated under EU directives.
The Protocol to the agreement provides safeguards against abuse of the exchange of information provisions.
AS per the agreement, requests for information from the tax authorities of one country to the other must be accompanied by relevance of the information to the request and conformity of the request with the law and administrative practices of the contracting state requesting it.
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Additionally, information will be provided only if the contracting state making the request has reciprocal provisions or applies appropriate administrative practices for the provision of the information requested.