EU list of non-cooperative jurisdictions for tax purposes

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On 21 December 2021, amendments to the Income Tax Law and Special Defence Contribution Law were published in the Cyprus Government Gazette for the introduction of  tax measures that will apply in Cyprus from 31 December 2022 in relation to jurisdictions included on the EU blacklisted jurisdictions for tax purposes.


In accordance with the Law amendments, Cyprus will apply withholding tax on certain outbound payments of dividends, interest and royalties, if the recipient is a company in an EU blacklisted jurisdiction, as follows:


  • Dividends at the rate of 17%
  • Interest at the rate of 30%
  • Royalties at the rate of 10%

The list adopted by the Ecofin Council on 4 October 2022 is composed of:


  1. American Samoa
  2. Anguilla
  3. Bahamas
  4. Fiji
  5. Guam
  6. Palau
  7. Panama
  8. Samoa
  9. Trinidad and Tobago
  10. Turks and Caicos Islands
  11. US Virgin Islands
  12. Vanuatu

In accordance with the Law amendments the defensive tax measures shall apply to companies that are:


  • resident in an EU blacklisted jurisdiction; or
  • incorporated / registered in such jurisdiction; and
  • not a tax resident in another jurisdiction that is not listed in the EU blacklist.
This note is intended to provide general information on the subject and does not constitute legal advice. For further information on the subject and for specific legal advice please contact us.

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