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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Cyprus: double taxation agreement, Article 18: Governmental functions

(1) Remuneration (other than pensions) paid out of public funds of the United Kingdom or Northern Ireland or of the funds of any local authority in the United Kingdom to any individual in respect of services rendered to the Government of the United Kingdom or Northern Ireland or a local authority in the United Kingdom in the discharge of functions of a governmental nature, shall be taxable only in the United Kingdom unless the individual is a Cyprus national without also being a United Kingdom national.

(2) Remuneration (other than pensions) paid by, or out of funds created by, Cyprus or a local authority thereof to any individual in respect of services rendered to the Government of Cyprus or a local authority thereof, in the discharge of functions of a governmental nature, shall be taxable only in Cyprus unless the individual is a United Kingdom national without also being a Cyprus national.

(3) The provisions of paragraphs (1) and (2) of this Article shall not apply to remuneration in respect of services rendered in connection with any trade or business.