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HMRC internal manual

Double Taxation Relief Manual

DT: Cyprus: double taxation agreement, Article 29: Entry into force

(1) This Convention shall enter into force when the last of all such things shall have been done in the United Kingdom and Cyprus as are necessary to give the Convention the force of law in the United Kingdom and Cyprus respectively, and shall thereupon have effect:

(a) in the United Kingdom:

(i) as respects income tax, for any year of assessment beginning on or after 6 April, 1973; and
(ii) as respects corporation tax, for any financial year beginning on or after 1 April, 1973;
(b) in Cyprus: as respects Cyprus tax for any year of assessment beginning on or after 1 January, 1973.

(2) Subject to the provisions of paragraph (3) of this Article the existing Arrangement shall cease to have effect as respects taxes to which this Convention in accordance with the provisions of paragraph (1) of this Article applies.

(3) Where any provision of the existing Arrangement would have afforded any greater relief from tax, any such provision as aforesaid shall continue to have effect for any year of assessment or financial year beginning before the entry into force of this Convention.

(4) The existing Arrangement between the United Kingdom of Great Britain and Northern Ireland and Cyprus shall terminate on the last date on which it has effect in accordance with the foregoing provisions of this Article.

(5) In this Article the term `the existing Arrangement` means the Arrangement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income which was in force between Her Majesty’s Government and the Government of Cyprus immediately before 16 August, 1960, when the independent sovereign Republic of Cyprus was established, and which has continued in force since that date between the Government of the United Kingdom and the Government of the Republic of Cyprus, as amended by the Agreement signed at Nicosia on 7 March 1968 and by the Supplementary Agreement signed at London on 18 May, 1973.