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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 22: Government income

(1) The Government of one of the Contracting States shall be exempt from tax in the other Contracting State in respect of any income derived by such Government from that other Contracting State.

(2) For the purposes of paragraph (1) of this Article, the term `Government`:

(a) in the case of Cyprus means the Government of Cyprus and shall include:

(i) the local authorities;
(ii) the Central Bank of Cyprus;
(iii) such institutions, the capital of which is wholly owned by the Government of Cyprus or the local authorities, as may be agreed from time to time between the Governments of the two Contracting States;
(b) in the case of the United Kingdom means the Government of the United Kingdom of Great Britain and Northern Ireland and shall include:

(i) the local authorities;
(ii) the Bank of England;
(iii) such institutions, the capital of which is wholly owned by the Government of the United Kingdom of Great Britain and Northern Ireland or the local authorities, as may be agreed from time to time between the Governments of the two Contracting States.