According to information published by the Cypriot Ministry of Finance, the Cyprus - United Kingdom Income Tax Treaty (2018) entered into force on 18 July 2018. The treaty generally applies from:
- 1 January 2019: for withholding and other taxes.
In the United Kingdom:
- 1 January 2019: for withholding taxes;
- 1 April 2019: for corporation taxes; and
- 6 April 2019: for income and capital gains taxes.
In Cyprus and the United Kingdom:
- 18 July 2018: for the provisions of article 25 (mutual agreement procedure) and article 26 (exchange of information).
From these dates, the new treaty will replace the Cyprus - United Kingdom Income Tax Treaty (1974).
However, the provisions of article 27 (Assistance in collection) shall not have effect until Cyprus confirms through diplomatic channels that it is able to provide such assistance under its domestic law whereupon (and to the extent permitted under that law) the provisions shall have effect without regard to the taxable period to which the revenue claim relates.
In addition, notwithstanding the entry into force of the new treaty, an individual who is entitled to the benefits of article 20 (Teachers) or article 21(Students and trainees) of the prior treaty at the time of entry into force of the new treaty shall continue to be entitled to such benefits until such time as the individual would have ceased to be entitled to such benefits if the prior treaty had remained in force, but in no case shall such entitlement continue for a period exceeding five years from the date of entry into force of the new treaty.
Details of the new treaty will be reported subsequently.