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HMRC internal manual

Double Taxation Relief Manual

DT: Cyprus: double taxation agreement, Article 24A: Excluded persons

Article 24A was inserted by SI80/1529 below

(1) The provisions of paragraphs (1)(b) and (c) and (2) of Article 11, paragraph (1) of Article 12 and paragraphs (1) and (V of Article 13 shall not apply to persons entitled to any special tax benefit under any of the Sections listed below of the Cyprus Income Tax Laws 1961 to 1977:
(a) Section 5(2)(c)(i) in so far as the tax charged is at a rate less than the rate prescribed for individuals in paragraph 1 of the Second Schedule to the Cyprus Income Tax Laws 1961 to 1977 or which may hereafter otherwise be prescribed for individuals generally;
(b) Section 8(w); (c) Section 28A: Provided that where an individual is entitled to a special tax benefit under Section 5(2)(c)(i) of the Cyprus Income Tax Laws 1961 to 1977 this Article shall not apply in relation to the first £1,500 sterling of the income arising in the United Kingdom in a year of assessment, and otherwise subject to tax in accordance with United Kingdom law, in respect of which that benefit is enjoyed.
(2) This Article shall apply also to any provision of Cyprus law enacted after 1 January 1978 which is of an identical or substantially similar character to the provisions mentioned in paragraph (1) of this Article.