Cyprus - Switzerland:
The treaty is based on the OECD Motel Tax Convention framework with a few modifications, and applies to taxes on income and on gains from the alienation of movable or immovable property. In the case of Switzerland, the treaty covers the income tax, the profits tax, the capital gains tax and the property tax. What concerns Cyprus, the treaty covers corporate and personal income tax, defence tax, capital gains tax and immovable property tax.
The following withholding taxes apply:
Dividends:
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zero in the case there is at least 10% participation by a tax resident company and the shares are held for at least one year or the shares are held by pension fund or a similar institution
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in all other cases, the withholding tax is 15%
Interest: 0% where the recipient of the interest is the beneficial owner of the income
Royalties: 0% where the recipient of the royalties is the beneficial owner of the income
Property: gains from the sale of property rich companies are taxed in the country where the property is located
Cyprus – Guernsey:
The treaty between Cyprus and Guernsey is based on the OECD Model Tax Convention framework with a few modifications, and applies to taxes on income and on gains from the alienation of movable or immovable property. In the case of Cyprus, it covers corporate and personal income tax, defence tax and capital gains tax. With regard to Guernsey, the treaty covers the income tax.
There is no withholding tax applied on dividends, interest and royalty payments.