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Convention between the Republic of Cyprus and Latvia

 

A Convention, for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, has been concluded between Cyprus and Latvia on 24 May 2016.

 

The Agreement shall apply to any person who is either a resident of one or both of the above Contracting States.

The main provisions of the Convention are amongst others, the following:

i.    Article 2 provides that the provisions of the Convention apply to taxes on income imposed to on behalf of a Contracting States, etc.

As taxes on income are considered all taxes imposed on total income or on elements of income ( i.e taxes on gains).

 

The existing taxes to which this Convention applies are:

IN THE CASE OF CYPRUS:

1.        the income tax;

2.        the corporate income tax;

3.        the special contribution for the Defence of the Republic;

4.        the capital gains tax;

 

IN THE CASE OF LATVIA:

1.      the enterprise income tax;

2.      the personal income tax;

 

ii.    Pursuant to Article 5 the term "permanent establishment" means a fixed place of business through which the business of an enterprise is wholly or partly carried on. The permanent establishment includes, inter alia, a place of management, a branch and an office etc.

 

iii.    Dividends, interest androyalties paid by a Company, resident in one Contracting State to a resident of the other are subjected to zero tax in the contacting state from which they originate provided that the beneficial owner of the dividend, interest, or royalty is a company ( but not a partnership) resident in the second contracting state.

 

In all other cases, tax payable is limited to 10% of the gross amount in the case of dividends and interest and 5% of the gross amount in the case of royalties. 

iv.    Article 13 refers to Capital gains as follows:

 

1.      Income or gains derived by a resident of a Contracting State from the alienation of immovable property, situated in the other Contracting State may be taxed in that other State.

2.      Gains on disposal of shares or comparable interests in a company or other entity deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State.

3.      Gains from the alienation of movable property forming part of the business property of apermanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State.

4.      Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State.

5.      Gains from the alienation of all other property are taxable only in the Contracting State of which the alienator is a resident.

 

v.    In Cyprus, the elimination of double taxation shall be made by a credit method. The Latvian tax paid shall be considered as a credit against Cyprus tax, payable in respect of any item of income derived from Latvia. The credit shall not, however, exceed that part of the Cyprus tax, as computed before the credit is given, which is appropriate to such items of income.

 

In Latvia double taxation shall be eliminated as follows:

 

  • Where a resident of Latvia derives income which, in accordance with this Convention, may be in Cyprus, unless a more favourable treatment is provided in its domestic law, Latvia shall allow as a deduction from the tax on the income of that resident, an amount equal to the income tax paid thereon in Cyprus.

 

  • Such deduction shall not, however, exceed that part of the income tax in Latvia as computed before the deduction is given, which is attributable, to the income which may be taxed in Cyprus.

 

 

For further information on this topic please contact Ms. Evi Lamprou at SOTERIS PITTAS & CO LLC, by telephone (+357 25 028460) or by fax (+357 25 028461) or by e-mail (elamprou@pittaslegal.com).

 

 

The content of this article is intended to provide a general guide to the subject matter. Specialist advise should be sought about your specific circumstances.

PUBLICATIONS

  • 24 Jan 2017

    Cyprus – Commercial Law - Promissory Notes

  • 16 Jan 2017

    Cyprus: Issuance of electronic disclosure by the Cypriot Courts

  • 27 Dec 2016

    Cyprus: Guidance on the impact of no signature on binding written agreements

  • 7 Dec 2016

    Cyprus: The new EU Electronic Signature Regulation 910/2014/EU

  • 1 Dec 2016

    CYPRUS: THE DUTY OF DISCLOSURE AT AN EX PARTE HEARING EXTENDS ALSO TO WITHOUT PREJUDICE CORRESPONDENCE

  • 21 Nov 2016

    CYPRUS: THE DUTY TO DISCLOSE AT EX PARTE HEARINGS EXTENDS ALSO TO RELEVANT LAW AND APPLICABLE LEGAL PRINCIPLES

  • 3 Nov 2016

    Convention between the Republic of Cyprus and Latvia

  • 26 Oct 2016

    Cyprus: Recognition and enforcement of judgments under the EU Regulation 1215/2012

  • 19 Oct 2016

    Cyprus: Worldwide freezing orders

  • 14 Oct 2016

    Cyprus: European Court of Justice importance in ruling on the Cyprus haircut case

  • 12 Oct 2016

    Cyprus: Changes to the Civil Procedure Rules by the Supreme Court of Cyprus

  • 28 Sep 2016

    Cyprus: Implementation of the EU Regulation No. 655/2014

  • 14 Sep 2016

    CYPRUS: ARBITRATION – ANTI-SUIT INJUNCTION ISSUED BY ARBITRATORS

  • 29 Aug 2016

    Cyprus:Announcement by the Department of Registrar of Companies and Official Receiver in relation to the Annual Company Fee

  • 28 Jul 2016

    Cyprus: Clarification on Cross border Insolvency which may be applied by the Cypriot Courts

  • 4 Jul 2016

    Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income between the Republic of Cyprus an...

  • 29 Jun 2016

    CYPRUS: The Grand Chamber of the European Court of Justice to decide on the haircut of Cyprus

  • 14 Jun 2016

    Enforcement of Judgments under the New Recast Regulation 1215/2012 and the issuance of protective measures

  • 7 Jun 2016

    CIRCULAR OF THE UNIT FOR COMBATING MONEY LAUNDERING - “PANAMA PAPERS”

  • 14 Apr 2016

    CYPRUS: JURISDICTION OF CYPRUS COURTS TO RECOGNISE AND ENFORCE FOREIGN JUDGMENTS AND FOREIGN ARBITRAL AWARDS IN CYPRUS

  • 7 Apr 2016

    AGREEMENT BETWEEN THE REPUBLIC OF CYPRUS AND THE FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA

  • 31 Mar 2016

    CYPRUS : English Court Guidance on Anti- suit Injunctions

  • 24 Mar 2016

    Cyprus: Implementation of the Common Reporting Standard by the Republic of Cyprus

  • 17 Mar 2016

    CYPRUS: English Court guidance on the wording of a Freezing Order

  • 9 Mar 2016

    CYPRUS : English Court Guidance on the liability of an agent – towards his principal for benefits and assets acquired during agency

  • 2 Mar 2016

    CYPRUS: LEGAL PROFESSIONAL PRIVILEGE

  • 22 Feb 2016

    Cyprus: The strict approach of the provisions laid under the New York Convention on the enforcement of foreign arbitral awards

  • 18 Feb 2016

    CYPRUS: LAW APPLICABLE TO CONTRACTUAL OBLIGATIONS – ROME I REGULATION

  • 11 Feb 2016

    CYPRUS: An update of the European Criminal Records Information System

  • 4 Feb 2016

    CYPRUS: Enforcement of Foreign Arbitral awards under New York Convention

  • 29 Jan 2016

    CYPRUS : WARRANT OF SEARCH ISSUED AGAINST A LAWYER CANCELLED DUE TO VIOLATION OF LEGAL PROFESSIONAL PRIVILEGE

  • 15 Jan 2016

    CYPRUS: English guidance on the principle of legal advice privilege

  • 7 Jan 2016

    Cyprus: Guidance of Cyprus Courts on issue of appointment of Lawyers by the Directors of a Company

NEWS

  • 21 Mar 2017

    METHODS OF PAYMENT / OTHER INSTRUMENTS - In House Seminar

  • 21 Mar 2017

    EU Regulation 655/14 - In House Seminar

  • 3 Mar 2017

    Update from the Registrar of Companies and Official Receiver

  • 22 Feb 2017

    LAWYER MONTHLY LEGAL AWARDS - Corporate Law Firm of the Year 2016 in Cyprus

  • 13 Feb 2017

    Update on the collection of information of financial instruments offered by the Cyprus Investment Firm

  • 22 Dec 2016

    DELETION OF COMPANIES DUE TO NON PAYMENT OF ANNUAL LEVY

  • 19 Dec 2016

    CHRISTMAS - NEW YEAR PREPARATIONS 2016-2017

  • 13 Dec 2016

    MEA Markets Business Awards 2016 - BOUTIQUE LAW FIRM of the year in Cyprus

  • 22 Nov 2016

    ORDER 30 OF THE CIVIL PROCEDURES RULES - In House Seminar

  • 9 Nov 2016

    SERVICE OF COURT DOCUMENTS - In House Seminar

  • 10 Oct 2016

    Cyprus- Health-NHS System

  • 4 Oct 2016

    CYPRUS PRIVATISATION OF THE CSE

  • 3 Oct 2016

    ACQUISITION INTERNATIONAL Awards 2016 - CORPORATE ADVISER of the year in Cyprus

  • 23 Sep 2016

    ACQ Global Awards 2016 - Corporate and Commercial LAW FIRM of the year in Cyprus

  • 20 Sep 2016

    No interest to buy loans from BoC - CySec

  • 15 Sep 2016

    The Cabinet has approved on Tuesday (13.0916) the revised scheme for granting Cypriot citizenship to non–Cypriot entrepreneurs/investors.

  • 30 May 2016

    Cyprus Investment Firms (CIFs) - In House Seminar

  • 24 May 2016

    Private Equity Law Firm of the year by CorporateINTL Global Awards 2016

  • 23 May 2016

    Due Diligence for Real Estate Conveyance - In House Seminar

  • 18 Apr 2016

    Ammendments in orders 25 & 30 - In House Seminar

  • 12 Apr 2016

    Participation of our members at the 5 Km Marathon - Run with Smile in Limassol

  • 7 Mar 2016

    Fire Protection and Safety - Training

  • 8 Feb 2016

    Highly Recommended Lawyer by Chambers Global Clients Guide 2016

  • 21 Dec 2015

    BASIC PRINCIPLES OF CORPORATE LAW - In House Seminar

  • 16 Dec 2015

    CHRISTMAS - NEW YEAR PREPARATIONS 2015-2016

  • 9 Dec 2015

    Mr. Soteris Pittas roundtable discussion with law students of UCLAN University - Cyprus

  • 1 Dec 2015

    Case Management - In House Seminar

  • 13 Nov 2015

    CONFERENCE “KIЕV ARBITRATION DAYS 2015: "THINK BIG"

  • 12 Nov 2015

    Mondaq's Contributor Most Read in Cyprus Award October 2015

  • 3 Nov 2015

    Our MD Mr. Soteris Pittas attended a seminar organised by the Ukrainian Bar Association and the Association of Judges of Ukraine in Kiev 02-11-2015

  • 27 Oct 2015

    Recent changes in Companies Law - in house seminar

  • 22 Oct 2015

    Acquisition International Best Boutique Law Firm - Cyprus Award

  • 28 Sep 2015

    Introduction to the Anti-Money Laundering Legislation - In house Seminar

  • 18 Dec 2014

    FIRST AID training session - Defibrillator

  • 18 Dec 2014

    CHRISTMAS - NEW YEAR PREPARATIONS 2014-2015

  • 11 Nov 2014

    CONFERENCE “KIЕV ARBITRATION DAYS 2014: "THINK BIG"

  • 21 Jul 2014

    25 years of progress – Grand Opening of New Premises (Press Release)

  • 10 Dec 2013

    CHRISTMAS - NEW YEAR PREPARATIONS 2013-2014

  • 21 Nov 2013

    Sponsor in Charity Event

  • 15 Oct 2013

    Participation of our members to charity event

  • 7 Oct 2013

    INTAX EXPRO - VIII Annual Conference and Exhibition

  • 4 Oct 2013

    Conference “Dispute Resolution in M&A Transactions: Tactics, Challenges, Defences“

  • 10 Jul 2013

    “Peculiarities of disputes in Cyprus in post-M&A and shareholder disputes

  • 10 Jul 2013

    Vote of Confidence for Cyprus Banks by Russian Businessmen

  • 10 Jul 2013

    New photos of the construction for our New Premises

  • 10 Jul 2013

    Visual Photos for our New Premises

  • 10 Jul 2013

    VAT Update on the changes as from 1 January 2010 in relation to the following matters

  • 10 Jul 2013

    The visit to Cyprus of the Russian President Mr. Dmitry Medvedev.

  • 10 Jul 2013

    Participation of Members of our Law Firm in Charity Event

  • 10 Jul 2013

    New Photos of the Construction of our new premises.

  • 10 Jul 2013

    Less Bureaucracy for Business Enterprises

  • 10 Jul 2013

    Latin Legal Maxims and Phrases

  • 10 Jul 2013

    Increase of the Cyprus VAT Rate, but still the second lowest in EU

  • 10 Jul 2013

    CONFERENCE “KIЕV ARBITRATION DAYS 2012: "THINK BIG"

  • 10 Jul 2013

    Commission takes action against Cyprus and other 11 Member States to implement the Shareholder’s rights Directive

  • 10 Jul 2013

    Beginning of the Construction for our new Premises

  • 10 Jul 2013

    Agreement for the Avoidance of Double Taxation between Cyprus and Slovenia

  • 10 Jul 2013

    Agreement for the Avoidance of Double Taxation between Cyprus and Qatar

  • 10 Jul 2013

    Agreement for the Avoidance of Double Taxation between Cyprus and Kuwait.

  • 10 Jul 2013

    ABA Conference / Moscow / September 2011