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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Cyprus: Source of income

For the purposes of the Elimination of double taxation Article, profits and income owned by a United Kingdom resident which may be taxed in Cyprus under the provisions of the agreement are deemed to arise from sources in Cyprus (Article 24(4)).

Interest is deemed to be derived from the country of which the payer is a resident (Article 12(3)).