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HMRC internal manual

Double Taxation Relief Manual

DT: Cyprus: double taxation agreement, Article 6: Limitation of relief

Where under any provision of this Convention income is relieved from tax in one of the Contracting States and, under the law in force in the other Contracting State, a person, in respect of the said income, is subject to tax by reference to the amount thereof which is remitted to or received in that other Contracting State and not by reference to the full amount thereof, then the relief to be allowed under this Convention in the first mentioned Contracting State shall apply only to so much of the income as is remitted to or received in the other Contracting State.